THE SECURITIES ACT OF 1933 | ☒ |
Pre-Effective Amendment No. | ☐ |
Post-Effective Amendment No. 71 | ☒ |
THE INVESTMENT COMPANY ACT OF 1940 | ☒ |
Amendment No. 72 | ☒ |
Christopher O. Petersen, Esq.
c/o Columbia Management Investment Advisers, LLC 225 Franklin Street Boston, Massachusetts 02110 |
Ryan C. Larrenaga, Esq
c/o Columbia Management Investment Advisers, LLC 225 Franklin Street Boston, Massachusetts 02110 |
SUMMARIES OF THE FUNDS
Investment Objective(s), Fees and Expenses of the Fund, Principal Investment Strategies, Principal Risks, Performance Information, Fund Management, Purchase and Sale of Fund Shares, Tax Information, Payments to Broker-Dealers and Other Financial Intermediaries |
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MORE INFORMATION ABOUT THE FUNDS
Investment Objective(s), Principal Investment Strategies, Principal Risks, Portfolio Management |
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Prospectus 2020 | 1 |
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2 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $80 | $249 | $433 | $966 |
Class 2 (whether or not shares are redeemed) | $105 | $328 | $569 | $1,259 |
Class 3 (whether or not shares are redeemed) | $93 | $290 | $504 | $1,120 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
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Best | 3rd Quarter 2010 | 9.92% |
Worst
|
3rd Quarter 2011 | -9.63% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 06/25/2014 | 22.96% | 7.62% | 9.79% |
Class 2 | 06/25/2014 | 22.66% | 7.35% | 9.55% |
Class 3 | 04/30/1986 | 22.78% | 7.45% | 9.69% |
Blended Benchmark (consisting of 60% S&P 500 Index and 40% Bloomberg Barclays U.S. Aggregate Bond Index) (reflects no deductions for fees, expenses or taxes) | 22.18% | 8.37% | 9.77% | |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.70% | 13.56% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.75% |
10 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Guy Pope, CFA | Senior Portfolio Manager and Head of Contrarian Core Strategy | Lead Portfolio Manager | 2011 | |||
Jason Callan | Senior Portfolio Manager and Head of Structured Assets | Portfolio Manager | 2018 | |||
Gregory Liechty | Senior Portfolio Manager | Portfolio Manager | 2011 | |||
Ronald Stahl, CFA | Senior Portfolio Manager and Head of Short Duration and Stable Value Team | Portfolio Manager | 2011 |
Prospectus 2020 | 11 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $67 | $211 | $368 | $822 |
Class 2 (whether or not shares are redeemed) | $93 | $290 | $504 | $1,120 |
Class 3 (whether or not shares are redeemed) | $81 | $252 | $439 | $978 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2012 | 14.46% |
Worst
|
3rd Quarter 2011 | -14.52% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 24.78% | 10.28% | 13.52% |
Class 2 | 05/03/2010 | 24.46% | 10.00% | 13.24% |
Class 3 | 10/13/1981 | 24.63% | 10.14% | 13.37% |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.70% | 13.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Condon, CFA, CAIA* | Senior Portfolio Manager and Head of Quantitative Strategies | Co-Portfolio Manager | 2010 | |||
Peter Albanese | Senior Portfolio Manager | Co-Portfolio Manager | 2014 | |||
Raghavendran Sivaraman, Ph.D., CFA | Senior Portfolio Manager | Co-Portfolio Manager | December 2019 |
* | Brian Condon has announced that he plans to retire from the Investment Manager, on May 31, 2020. Until then, Mr. Condon will continue to serve as a Co-Portfolio Manager of the Fund. |
16 | Prospectus 2020 |
Prospectus 2020 | 17 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $81 | $252 | $439 | $978 |
Class 2 (whether or not shares are redeemed) | $106 | $331 | $574 | $1,271 |
Class 3 (whether or not shares are redeemed) | $94 | $293 | $509 | $1,131 |
18 | Prospectus 2020 |
Prospectus 2020 | 19 |
20 | Prospectus 2020 |
Prospectus 2020 | 21 |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 24.07% | 8.16% | 10.13% |
Class 2 | 05/03/2010 | 23.76% | 7.89% | 9.85% |
Class 3 | 09/15/1999 | 23.92% | 8.03% | 10.00% |
MSCI USA High Dividend Yield Index (Net) (reflects reinvested dividends net of
withholding taxes but reflects no deductions for fees, expenses or other taxes) |
21.26% | 9.78% | 12.65% | |
Russell 1000 Value Index (reflects no deductions for fees, expenses or taxes) | 26.54% | 8.29% | 11.80% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David King, CFA | Senior Portfolio Manager | Lead Portfolio Manager | 2018 | |||
Yan Jin | Senior Portfolio Manager | Portfolio Manager | 2018 |
22 | Prospectus 2020 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $123 | $384 | $665 | $1,466 |
Class 2 (whether or not shares are redeemed) | $149 | $462 | $797 | $1,746 |
Class 3 (whether or not shares are redeemed) | $136 | $425 | $734 | $1,613 |
Prospectus 2020 | 23 |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
28 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
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Best | 3rd Quarter 2010 | 19.59% |
Worst
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3rd Quarter 2011 | -24.47% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 31.50% | 7.82% | 4.84% |
Class 2 | 05/03/2010 | 31.13% | 7.54% | 4.58% |
Class 3 | 05/01/2000 | 31.29% | 7.67% | 4.70% |
MSCI Emerging Markets Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 18.42% | 5.61% | 3.68% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Dara White, CFA | Senior Portfolio Manager | Lead Portfolio Manager | 2012 | |||
Robert Cameron | Senior Portfolio Manager | Portfolio Manager | 2012 | |||
Young Kim | Senior Portfolio Manager | Portfolio Manager | 2015 | |||
Perry Vickery, CFA | Senior Portfolio Manager | Portfolio Manager | 2017 | |||
Derek Lin, CFA
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Portfolio Manager | Portfolio Manager | January 2020 |
Prospectus 2020 | 29 |
30 | Prospectus 2020 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.61% for Class 1, 0.86% for Class 2 and 0.735% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $62 | $245 | $443 | $1,016 |
Class 2 (whether or not shares are redeemed) | $88 | $324 | $579 | $1,308 |
Class 3 (whether or not shares are redeemed) | $76 | $286 | $514 | $1,169 |
Prospectus 2020 | 31 |
32 | Prospectus 2020 |
Prospectus 2020 | 33 |
34 | Prospectus 2020 |
Prospectus 2020 | 35 |
36 | Prospectus 2020 |
Prospectus 2020 | 37 |
38 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 3rd Quarter 2010 | 8.20% |
Worst
|
4th Quarter 2016 | -7.62% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 10.96% | 0.70% | 1.41% |
Class 2 | 05/03/2010 | 10.75% | 0.46% | 1.17% |
Class 3 | 05/01/1996 | 10.91% | 0.58% | 1.29% |
Bloomberg Barclays Global Aggregate Hedged USD Index (reflects no deductions for fees, expenses or taxes) | 8.22% | 3.57% | 4.08% | |
Bloomberg Barclays Global Credit Hedged USD Index (reflects no deductions for fees, expenses or taxes) | 11.85% | 4.36% | 5.08% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Gene Tannuzzo, CFA | Deputy Global Head of Fixed Income and Senior Portfolio Manager | Lead Portfolio Manager | 2014 | |||
Tim Jagger | Head of Emerging Market Debt and Senior Portfolio Manager | Portfolio Manager | 2018 | |||
Ryan Staszewski, CFA | Senior Portfolio Manager | Portfolio Manager | 2018 |
Prospectus 2020 | 39 |
40 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.45% for Class 1, 0.70% for Class 2 and 0.575% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $46 | $149 | $261 | $590 |
Class 2 (whether or not shares are redeemed) | $72 | $228 | $399 | $893 |
Class 3 (whether or not shares are redeemed) | $59 | $190 | $333 | $748 |
Prospectus 2020 | 41 |
42 | Prospectus 2020 |
Prospectus 2020 | 43 |
44 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 2nd Quarter 2019 | 0.51% |
Worst
|
1st Quarter 2010 | 0.002% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 1.89% | 0.77% | 0.39% |
Class 2 | 05/03/2010 | 1.64% | 0.62% | 0.31% |
Class 3 | 10/13/1981 | 1.77% | 0.69% | 0.35% |
Prospectus 2020 | 45 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.67% for Class 1, 0.92% for Class 2 and 0.795% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $68 | $236 | $418 | $945 |
Class 2 (whether or not shares are redeemed) | $94 | $315 | $554 | $1,239 |
Class 3 (whether or not shares are redeemed) | $82 | $277 | $489 | $1,099 |
46 | Prospectus 2020 |
Prospectus 2020 | 47 |
48 | Prospectus 2020 |
Prospectus 2020 | 49 |
50 | Prospectus 2020 |
Prospectus 2020 | 51 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.75% |
Worst
|
3rd Quarter 2011 | -5.71% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 17.00% | 5.79% | 7.41% |
Class 2 | 05/03/2010 | 16.52% | 5.51% | 7.13% |
Class 3 | 05/01/1996 | 16.72% | 5.66% | 7.26% |
ICE BofA US Cash Pay High Yield Constrained Index (reflects no deductions for fees, expenses or taxes) | 14.40% | 6.13% | 7.47% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Lavin, CFA | Senior Portfolio Manager and Head of U.S. High Yield, Co-Head Global High Yield | Lead Portfolio Manager | 2010 | |||
Daniel J. DeYoung | Portfolio Manager | Portfolio Manager | 2019 |
52 | Prospectus 2020 |
Prospectus 2020 | 53 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.67% for Class 1, 0.92% for Class 2 and 0.795% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $68 | $230 | $405 | $912 |
Class 2 (whether or not shares are redeemed) | $94 | $308 | $540 | $1,207 |
Class 3 (whether or not shares are redeemed) | $82 | $271 | $475 | $1,066 |
54 | Prospectus 2020 |
Prospectus 2020 | 55 |
56 | Prospectus 2020 |
Prospectus 2020 | 57 |
58 | Prospectus 2020 |
Prospectus 2020 | 59 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.48% |
Worst
|
4th Quarter 2018 | -4.66% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 16.47% | 5.58% | 7.09% |
Class 2 | 05/03/2010 | 16.12% | 5.34% | 6.85% |
Class 3 | 06/01/2004 | 16.23% | 5.46% | 6.97% |
ICE BofA BB-B US Cash Pay High Yield Constrained Index (reflects no deductions for fees, expenses or taxes) | 15.09% | 6.11% | 7.40% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Lavin, CFA | Senior Portfolio Manager and Head of U.S. High Yield, Co-Head Global High Yield | Lead Portfolio Manager | 2004 | |||
Daniel J. DeYoung | Portfolio Manager | Portfolio Manager | 2019 |
60 | Prospectus 2020 |
Prospectus 2020 | 61 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $50 | $157 | $274 | $616 |
Class 2 (whether or not shares are redeemed) | $76 | $237 | $411 | $918 |
Class 3 (whether or not shares are redeemed) | $63 | $199 | $346 | $774 |
62 | Prospectus 2020 |
Prospectus 2020 | 63 |
64 | Prospectus 2020 |
Prospectus 2020 | 65 |
66 | Prospectus 2020 |
Prospectus 2020 | 67 |
68 | Prospectus 2020 |
Prospectus 2020 | 69 |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 9.25% | 3.65% | 4.39% |
Class 2 | 05/03/2010 | 9.03% | 3.38% | 4.15% |
Class 3 | 10/13/1981 | 9.12% | 3.51% | 4.27% |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.75% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jason Callan | Senior Portfolio Manager and Head of Structured Assets | Lead Portfolio Manager | 2016 | |||
Gene Tannuzzo, CFA | Deputy Global Head of Fixed Income and Senior Portfolio Manager | Portfolio Manager | 2017 |
70 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $75 | $233 | $406 | $906 |
Class 2 (whether or not shares are redeemed) | $100 | $312 | $542 | $1,201 |
Class 3 (whether or not shares are redeemed) | $88 | $274 | $477 | $1,061 |
Prospectus 2020 | 71 |
72 | Prospectus 2020 |
Prospectus 2020 | 73 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2012 | 17.27% |
Worst
|
4th Quarter 2018 | -17.49% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 35.90% | 13.07% | 14.16% |
Class 2 | 05/03/2010 | 35.53% | 12.79% | 13.88% |
Class 3 | 09/15/1999 | 35.76% | 12.93% | 14.03% |
Russell 1000 Growth Index (reflects no deductions for fees, expenses or taxes) | 36.39% | 14.63% | 15.22% |
74 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Melda Mergen, CFA, CAIA | Senior Portfolio Manager, Managing Director and Deputy Global Head of Equities | Co-Portfolio Manager | November 2019 | |||
Peter Santoro, CFA | Senior Portfolio Manager | Co-Portfolio Manager | November 2019 | |||
Tchintcia Barros, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2015 |
Prospectus 2020 | 75 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $27 | $84 | $146 | $331 |
Class 2 (whether or not shares are redeemed) | $52 | $164 | $285 | $640 |
Class 3 (whether or not shares are redeemed) | $40 | $125 | $219 | $493 |
76 | Prospectus 2020 |
Prospectus 2020 | 77 |
78 | Prospectus 2020 |
Prospectus 2020 | 79 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 13.54% |
Worst
|
3rd Quarter 2011 | -13.96% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 04/25/2011 | 31.14% | 11.34% | 13.18% |
Class 2 | 04/25/2011 | 30.79% | 11.06% | 12.93% |
Class 3 | 05/01/2000 | 31.00% | 11.21% | 13.07% |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.70% | 13.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Christopher Lo, CFA | Senior Portfolio Manager | Lead Portfolio Manager | 2014 | |||
Vadim Shteyn | Associate Portfolio Manager | Portfolio Manager | 2011 |
80 | Prospectus 2020 |
Prospectus 2020 | 81 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.79% for Class 1, 1.04% for Class 2 and 0.915% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $81 | $272 | $479 | $1,076 |
Class 2 (whether or not shares are redeemed) | $106 | $350 | $614 | $1,367 |
Class 3 (whether or not shares are redeemed) | $94 | $313 | $549 | $1,228 |
82 | Prospectus 2020 |
Prospectus 2020 | 83 |
84 | Prospectus 2020 |
Prospectus 2020 | 85 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 18.52% |
Worst
|
3rd Quarter 2011 | -24.63% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 35.18% | 11.33% | 11.17% |
Class 2 | 05/03/2010 | 34.83% | 11.06% | 10.91% |
Class 3 | 05/01/2001 | 34.98% | 11.19% | 11.04% |
Russell Midcap Growth Index (reflects no deductions for fees, expenses or taxes) | 35.47% | 11.60% | 14.24% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Matthew A. Litfin, CFA | Director of Research (U.S.) and Senior Portfolio Manager at Columbia Wanger Asset Management, LLC, an investment advisory affiliate of Columbia Management Investment Advisers, LLC, and Portfolio Manager | Lead Portfolio Manager | 2018 | |||
Erika K. Maschmeyer, CFA | Senior Portfolio Manager at Columbia Wanger Asset Management, LLC, an investment advisory affiliate of Columbia Management Investment Advisers, LLC, and Portfolio Manager | Portfolio Manager | 2018 | |||
John L. Emerson, CFA | Senior Portfolio Manager at Columbia Wanger Asset Management, LLC, an investment advisory affiliate of Columbia Management Investment Advisers, LLC, and Portfolio Manager | Portfolio Manager | 2018 |
86 | Prospectus 2020 |
Prospectus 2020 | 87 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $91 | $284 | $493 | $1,096 |
Class 2 (whether or not shares are redeemed) | $116 | $362 | $628 | $1,386 |
Class 3 (whether or not shares are redeemed) | $104 | $325 | $563 | $1,248 |
88 | Prospectus 2020 |
Prospectus 2020 | 89 |
90 | Prospectus 2020 |
Prospectus 2020 | 91 |
92 | Prospectus 2020 |
Prospectus 2020 | 93 |
94 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 3rd Quarter 2010 | 18.06% |
Worst
|
3rd Quarter 2011 | -20.53% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 25.47% | 5.70% | 5.69% |
Class 2 | 05/03/2010 | 25.15% | 5.42% | 5.42% |
Class 3 | 01/13/1992 | 25.32% | 5.57% | 5.57% |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes
but reflects no deductions for fees, expenses or other taxes) |
22.01% | 5.67% | 5.50% |
Prospectus 2020 | 95 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Fred Copper, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2018 | |||
Daisuke Nomoto, CMA (SAAJ) | Senior Portfolio Manager | Co-Portfolio Manager | 2018 |
96 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.72% for Class 1, 0.97% for Class 2 and 0.845% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $74 | $232 | $405 | $906 |
Class 2 (whether or not shares are redeemed) | $99 | $311 | $541 | $1,200 |
Class 3 (whether or not shares are redeemed) | $87 | $273 | $476 | $1,060 |
Prospectus 2020 | 97 |
98 | Prospectus 2020 |
Prospectus 2020 | 99 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2012 | 16.14% |
Worst
|
3rd Quarter 2011 | -19.21% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 26.75% | 8.96% | 12.78% |
Class 2 | 05/03/2010 | 26.43% | 8.68% | 12.51% |
Class 3 | 02/04/2004 | 26.54% | 8.81% | 12.64% |
Russell 1000 Value Index (reflects no deductions for fees, expenses or taxes) | 26.54% | 8.29% | 11.80% | |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.70% | 13.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Richard Rosen | Senior Portfolio Manager | Lead Portfolio Manager | 2008 | |||
Richard Taft | Senior Portfolio Manager | Portfolio Manager | 2016 |
100 | Prospectus 2020 |
Prospectus 2020 | 101 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.81% for Class 1, 1.06% for Class 2 and 0.935% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $83 | $274 | $481 | $1,078 |
Class 2 (whether or not shares are redeemed) | $108 | $352 | $616 | $1,368 |
Class 3 (whether or not shares are redeemed) | $96 | $315 | $551 | $1,230 |
102 | Prospectus 2020 |
Prospectus 2020 | 103 |
104 | Prospectus 2020 |
Prospectus 2020 | 105 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 16.09% |
Worst
|
3rd Quarter 2011 | -23.02% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 31.62% | 7.04% | 11.24% |
Class 2 | 05/03/2010 | 31.25% | 6.80% | 10.99% |
Class 3 | 05/02/2005 | 31.42% | 6.93% | 11.11% |
Russell Midcap Value Index (reflects no deductions for fees, expenses or taxes) | 27.06% | 7.62% | 12.41% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Kari Montanus | Senior Portfolio Manager | Lead Portfolio Manager | 2018 | |||
Jonas Patrikson, CFA | Senior Portfolio Manager | Portfolio Manager | 2014 |
106 | Prospectus 2020 |
Prospectus 2020 | 107 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.85% for Class 1, 1.10% for Class 2 and 0.975% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $87 | $314 | $560 | $1,265 |
Class 2 (whether or not shares are redeemed) | $112 | $392 | $694 | $1,550 |
Class 3 (whether or not shares are redeemed) | $100 | $355 | $630 | $1,414 |
108 | Prospectus 2020 |
Prospectus 2020 | 109 |
110 | Prospectus 2020 |
Prospectus 2020 | 111 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2012 | 16.33% |
Worst
|
3rd Quarter 2011 | -24.59% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 17.74% | 5.00% | 10.67% |
Class 2 | 05/03/2010 | 17.44% | 4.75% | 10.40% |
Class 3 | 09/15/1999 | 17.59% | 4.88% | 10.54% |
Russell 2000 Value Index (reflects no deductions for fees, expenses or taxes) | 22.39% | 6.99% | 10.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Kari Montanus | Senior Portfolio Manager | Lead Portfolio Manager | 2014 | |||
Jonas Patrikson, CFA | Senior Portfolio Manager | Portfolio Manager | 2018 |
112 | Prospectus 2020 |
Prospectus 2020 | 113 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $46 | $144 | $252 | $567 |
Class 2 (whether or not shares are redeemed) | $72 | $224 | $390 | $871 |
Class 3 (whether or not shares are redeemed) | $59 | $186 | $324 | $726 |
114 | Prospectus 2020 |
Prospectus 2020 | 115 |
116 | Prospectus 2020 |
Prospectus 2020 | 117 |
118 | Prospectus 2020 |
Prospectus 2020 | 119 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 2.54% |
Worst
|
2nd Quarter 2013 | -2.06% |
120 | Prospectus 2020 |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 6.73% | 3.18% | 2.61% |
Class 2 | 05/03/2010 | 6.50% | 2.93% | 2.36% |
Class 3 | 09/15/1999 | 6.61% | 3.05% | 2.49% |
Bloomberg Barclays U.S. Mortgage-Backed Securities Index (reflects no deductions for fees, expenses or taxes) | 6.35% | 2.58% | 3.15% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jason Callan | Senior Portfolio Manager and Head of Structured Assets | Co-Portfolio Manager | 2012 | |||
Tom Heuer, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2012 | |||
Ryan Osborn, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2019 |
Prospectus 2020 | 121 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.65% for Class 1, 0.90% for Class 2 and 0.775% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $66 | $221 | $389 | $877 |
Class 2 (whether or not shares are redeemed) | $92 | $300 | $525 | $1,173 |
Class 3 (whether or not shares are redeemed) | $80 | $262 | $460 | $1,032 |
122 | Prospectus 2020 |
Prospectus 2020 | 123 |
124 | Prospectus 2020 |
Prospectus 2020 | 125 |
126 | Prospectus 2020 |
Prospectus 2020 | 127 |
128 | Prospectus 2020 |
Prospectus 2020 | 129 |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 7.90% | 3.43% | 3.99% |
Class 2 | 05/03/2010 | 7.63% | 3.15% | 3.74% |
Class 3 | 09/13/2004 | 7.81% | 3.29% | 3.86% |
Bloomberg Barclays World Government Inflation-Linked Bond Index USD Hedged (reflects no deductions for fees, expenses or taxes) | 8.38% | 4.08% | 4.52% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Christopher Allen, CFA | Managing Director of BIL | Co-Portfolio Manager | 2018 | |||
Akiva Dickstein | Managing Director of BlackRock | Co-Portfolio Manager | 2018 | |||
Emanuella Enenajor | Director of BlackRock | Co-Portfolio Manager | May 2020 |
130 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $81 | $252 | $439 | $978 |
Class 2 (whether or not shares are redeemed) | $106 | $331 | $574 | $1,271 |
Class 3 (whether or not shares are redeemed) | $94 | $293 | $509 | $1,131 |
Prospectus 2020 | 131 |
132 | Prospectus 2020 |
Prospectus 2020 | 133 |
134 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 3rd Quarter 2010 | 13.89% |
Worst
|
3rd Quarter 2011 | -20.17% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 28.20% | 10.11% | 12.70% |
Class 2 | 05/03/2010 | 27.85% | 9.84% | 12.43% |
Class 3 | 02/04/2004 | 28.01% | 9.98% | 12.58% |
Russell Midcap Value Index (reflects no deductions for fees, expenses or taxes) | 27.06% | 7.62% | 12.41% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Gary Miller | Chief Investment Officer of Victory Capital’s Sycamore Capital | Lead Portfolio Manager | 2012 | |||
Jeffrey Graff, CFA | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 | |||
Gregory Conners | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 | |||
James Albers, CFA | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 | |||
Michael Rodarte, CFA | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 |
Prospectus 2020 | 135 |
136 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.69% for Class 1, 0.94% for Class 2 and 0.815% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $70 | $223 | $389 | $870 |
Class 2 (whether or not shares are redeemed) | $96 | $302 | $525 | $1,165 |
Class 3 (whether or not shares are redeemed) | $84 | $264 | $460 | $1,024 |
Prospectus 2020 | 137 |
138 | Prospectus 2020 |
Prospectus 2020 | 139 |
140 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 12.28% |
Worst
|
3rd Quarter 2011 | -15.48% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 26.59% | 9.14% | 10.29% |
Class 2 | 05/03/2010 | 26.21% | 8.87% | 10.03% |
Class 3 | 05/01/2006 | 26.38% | 9.01% | 10.16% |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.70% | 13.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Bruce Jacobs, Ph.D. | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | May 2019 | |||
Kenneth Levy, CFA | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | May 2019 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jeffrey Rottinghaus, CPA |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | May 2019 |
Prospectus 2020 | 141 |
142 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
(b) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.88% for Class 1, 1.13% for Class 2 and 1.005% for Class 3. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $90 | $283 | $492 | $1,095 |
Class 2 (whether or not shares are redeemed) | $115 | $361 | $627 | $1,385 |
Class 3 (whether or not shares are redeemed) | $103 | $324 | $562 | $1,247 |
Prospectus 2020 | 143 |
144 | Prospectus 2020 |
Prospectus 2020 | 145 |
146 | Prospectus 2020 |
Prospectus 2020 | 147 |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | 19.80% | 4.85% | 9.01% |
Class 2 | 05/03/2010 | 19.53% | 4.58% | 8.74% |
Class 3 | 08/14/2001 | 19.66% | 4.72% | 8.87% |
Russell 2000 Value Index (reflects no deductions for fees, expenses or taxes) | 22.39% | 6.99% | 10.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Bruce Jacobs, Ph.D. | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | 2017 | |||
Kenneth Levy, CFA | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | 2017 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Karen L. Bowie, CFA | Senior Vice President and Portfolio Manager of Nuveen Asset Management | Co-Portfolio Manager | 2017 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Mark Dickherber, CFA, CPA | Principal, Director of Small Cap Strategies of SBH | Co-Portfolio Manager | 2014 | |||
Shaun Nicholson | Principal, Senior Portfolio Manager of SBH | Co-Portfolio Manager | 2014 |
148 | Prospectus 2020 |
Prospectus 2020 | 149 |
150 | Prospectus 2020 |
Prospectus 2020 | 151 |
152 | Prospectus 2020 |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
Prospectus 2020 | 153 |
154 | Prospectus 2020 |
Prospectus 2020 | 155 |
156 | Prospectus 2020 |
Prospectus 2020 | 157 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Guy Pope, CFA | Senior Portfolio Manager and Head of Contrarian Core Strategy | Lead Portfolio Manager | 2011 | |||
Jason Callan | Senior Portfolio Manager and Head of Structured Assets | Portfolio Manager | 2018 | |||
Gregory Liechty | Senior Portfolio Manager | Portfolio Manager | 2011 | |||
Ronald Stahl, CFA | Senior Portfolio Manager and Head of Short Duration and Stable Value Team | Portfolio Manager | 2011 |
158 | Prospectus 2020 |
■ | Valuation factors, such as earnings and cash flow relative to market values; |
■ | Catalyst factors, such as relative stock price performance, business momentum, and short interest measures; and |
■ | Quality factors, such as quality of earnings and financial strength. |
Prospectus 2020 | 159 |
160 | Prospectus 2020 |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
Prospectus 2020 | 161 |
162 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Condon, CFA, CAIA* | Senior Portfolio Manager and Head of Quantitative Strategies | Co-Portfolio Manager | 2010 | |||
Peter Albanese | Senior Portfolio Manager | Co-Portfolio Manager | 2014 | |||
Raghavendran Sivaraman, Ph.D., CFA | Senior Portfolio Manager | Co-Portfolio Manager | December 2019 |
* | Brian Condon has announced that he plans to retire from the Investment Manager, on May 31, 2020. Until then, Mr. Condon will continue to serve as a Co-Portfolio Manager of the Fund. |
Prospectus 2020 | 163 |
■ | Current yield; |
■ | Dividend growth capability (considering a company’s financial statements and management’s ability to increase the dividend if it chooses to do so) and dividend history; |
■ | Balance sheet strength; |
■ | Earnings per share and free cash flow sustainability; and/or |
■ | Dividend payout ratio. |
164 | Prospectus 2020 |
Prospectus 2020 | 165 |
166 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David King, CFA | Senior Portfolio Manager | Lead Portfolio Manager | 2018 | |||
Yan Jin | Senior Portfolio Manager | Portfolio Manager | 2018 |
Prospectus 2020 | 167 |
■ | various measures of valuation, including price-to-cash flow, price-to-earnings, price-to-sales, price-to-book value and discounted cash flow. The Investment Manager believes that companies with lower valuations are generally more likely to provide opportunities for capital appreciation; |
■ | potential indicators of stock price appreciation, such as anticipated earnings growth, company restructuring, changes in management, business model changes, new product opportunities, or anticipated improvements in macroeconomic factors; |
■ | the financial condition and management of a company, including its competitive position, the quality of its balance sheet and earnings, its future prospects, and the potential for growth and stock price appreciation; and/or |
■ | overall economic and market conditions. |
168 | Prospectus 2020 |
Prospectus 2020 | 169 |
170 | Prospectus 2020 |
Prospectus 2020 | 171 |
172 | Prospectus 2020 |
Prospectus 2020 | 173 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Dara White, CFA | Senior Portfolio Manager | Lead Portfolio Manager | 2012 | |||
Robert Cameron | Senior Portfolio Manager | Portfolio Manager | 2012 | |||
Young Kim | Senior Portfolio Manager | Portfolio Manager | 2015 | |||
Perry Vickery, CFA | Senior Portfolio Manager | Portfolio Manager | 2017 | |||
Derek Lin, CFA
|
Portfolio Manager | Portfolio Manager | January 2020 |
174 | Prospectus 2020 |
Prospectus 2020 | 175 |
176 | Prospectus 2020 |
Prospectus 2020 | 177 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency strategy by a Fund may be reduced by the Fund's inability to precisely match forward |
178 | Prospectus 2020 |
contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A bond (or debt instrument) future is a derivative that is an agreement for the contract holder to buy or sell a bond or other debt instrument, a basket of bonds or other debt instrument, or the bonds or other debt instruments in an index on a specified date at a predetermined price. The buyer (long position) of a bond future is obliged to buy the underlying reference at the agreed price on expiry of the future. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
Prospectus 2020 | 179 |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
■ | An inflation rate swap is a derivative typically used to transfer inflation risk from one party to another through an exchange of cash flows. In an inflation rate swap, one party pays a fixed rate on a notional principal amount, while the other party pays a floating rate linked to an inflation index, such as the Consumer Price Index (CPI). |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including LIBOR, swap rates, treasury rates and foreign interest rates. |
■ | Total return swaps are derivative swap transactions in which one party agrees to pay the other party an amount equal to the total return of a defined underlying reference during a specified period of time. In return, the other party would make periodic payments based on a fixed or variable interest rate or on the total return of a different underlying reference. |
180 | Prospectus 2020 |
Prospectus 2020 | 181 |
182 | Prospectus 2020 |
Prospectus 2020 | 183 |
184 | Prospectus 2020 |
Prospectus 2020 | 185 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Gene Tannuzzo, CFA | Deputy Global Head of Fixed Income and Senior Portfolio Manager | Lead Portfolio Manager | 2014 | |||
Tim Jagger | Head of Emerging Market Debt and Senior Portfolio Manager | Portfolio Manager | 2018 | |||
Ryan Staszewski, CFA | Senior Portfolio Manager | Portfolio Manager | 2018 |
186 | Prospectus 2020 |
■ | Considers opportunities and risks given current interest rates and anticipated interest rates. |
■ | Purchases securities based on the timing of cash flows in and out of the Fund. |
■ | Considers the impact of the purchase on the Fund’s average maturity and duration. |
■ | Considers a security’s yield, relative value and credit characteristics. |
■ | The issuer’s fundamentals are deteriorating. |
■ | Political, economic, or other events could affect the issuer’s performance. |
■ | The Investment Manager believes that it has identified a more attractive opportunity. |
■ | The issuer or the security no longer meets the security selection criteria described above. |
Prospectus 2020 | 187 |
188 | Prospectus 2020 |
Prospectus 2020 | 189 |
190 | Prospectus 2020 |
■ | Rigorous, in-house credit research using a proprietary risk and relative value rating system with the goal of generating strong risk-adjusted returns; |
■ | A process focused on seeking to identify issuers with improving credit quality characterized by several factors including: |
■ | stable and strengthening cash flows, |
■ | the ability to de-leverage through free cash flow, |
■ | asset valuations supporting debt, |
■ | strong management, |
■ | strong and sustainable market positioning, and/or |
■ | access to capital; |
■ | A top down assessment of broad economic and market conditions to determine quality and industry weightings; |
■ | Review of the legal documentation supporting the loan, including an analysis of the covenants and the rights and remedies of the lender. |
Prospectus 2020 | 191 |
■ | Deterioration in the issuer’s results relative to analyst expectations, |
■ | Inability of the issuer to de-leverage, |
■ | Reduced asset coverage for the issuer, |
■ | Deterioration in the issuer’s competitive position, |
■ | Reduced access to capital for the issuer, |
■ | Changes in the issuer’s management, |
■ | Whether the Investment Manager’s price target for the security has been achieved, and/or |
■ | The investment’s potential upside/downside compared to other investments or investment opportunities. |
192 | Prospectus 2020 |
Prospectus 2020 | 193 |
194 | Prospectus 2020 |
Prospectus 2020 | 195 |
196 | Prospectus 2020 |
Prospectus 2020 | 197 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Lavin, CFA | Senior Portfolio Manager and Head of U.S. High Yield, Co-Head Global High Yield | Lead Portfolio Manager | 2010 | |||
Daniel J. DeYoung | Portfolio Manager | Portfolio Manager | 2019 |
198 | Prospectus 2020 |
■ | Rigorous, in-house credit research using a proprietary risk and relative value rating system with the goal of generating strong risk-adjusted returns; |
■ | A process focused on seeking to identify issuers with improving credit quality characterized by several factors including: |
■ | stable and strengthening cash flows, |
■ | the ability to de-leverage through free cash flow, |
■ | asset valuations supporting debt, |
■ | strong management, |
■ | strong and sustainable market positioning, and/or |
■ | access to capital; |
■ | A top down assessment of broad economic and market conditions to determine quality and industry weightings; |
■ | Review of the legal documentation supporting the loan, including an analysis of the covenants and the rights and remedies of the lender. |
Prospectus 2020 | 199 |
■ | Deterioration in the issuer’s results relative to analyst expectations, |
■ | Inability of the issuer to de-leverage, |
■ | Reduced asset coverage for the issuer, |
■ | Deterioration in the issuer’s competitive position, |
■ | Reduced access to capital for the issuer, |
■ | Changes in the issuer’s management, |
■ | Whether the Investment Manager’s price target for the security has been achieved, and/or |
■ | The investment’s potential upside/downside compared to other investments or investment opportunities. |
200 | Prospectus 2020 |
Prospectus 2020 | 201 |
202 | Prospectus 2020 |
Prospectus 2020 | 203 |
204 | Prospectus 2020 |
Prospectus 2020 | 205 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Lavin, CFA | Senior Portfolio Manager and Head of U.S. High Yield, Co-Head Global High Yield | Lead Portfolio Manager | 2004 | |||
Daniel J. DeYoung | Portfolio Manager | Portfolio Manager | 2019 |
206 | Prospectus 2020 |
Prospectus 2020 | 207 |
208 | Prospectus 2020 |
Prospectus 2020 | 209 |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including LIBOR, swap rates, treasury rates and foreign interest rates. |
210 | Prospectus 2020 |
Prospectus 2020 | 211 |
212 | Prospectus 2020 |
Prospectus 2020 | 213 |
214 | Prospectus 2020 |
Prospectus 2020 | 215 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jason Callan | Senior Portfolio Manager and Head of Structured Assets | Lead Portfolio Manager | 2016 | |||
Gene Tannuzzo, CFA | Deputy Global Head of Fixed Income and Senior Portfolio Manager | Portfolio Manager | 2017 |
216 | Prospectus 2020 |
■ | overall economic and market conditions; and |
■ | the financial condition and management of a company, including its competitive position, the quality of its balance sheet and earnings, its future prospects, and the potential for growth and stock price appreciation. |
Prospectus 2020 | 217 |
218 | Prospectus 2020 |
Prospectus 2020 | 219 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Melda Mergen, CFA, CAIA | Senior Portfolio Manager, Managing Director and Deputy Global Head of Equities | Co-Portfolio Manager | November 2019 | |||
Peter Santoro, CFA | Senior Portfolio Manager | Co-Portfolio Manager | November 2019 | |||
Tchintcia Barros, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2015 |
220 | Prospectus 2020 |
Prospectus 2020 | 221 |
222 | Prospectus 2020 |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
Prospectus 2020 | 223 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Christopher Lo, CFA | Senior Portfolio Manager | Lead Portfolio Manager | 2014 | |||
Vadim Shteyn | Associate Portfolio Manager | Portfolio Manager | 2011 |
224 | Prospectus 2020 |
■ | overall economic and market conditions; and |
■ | the financial condition and management of a company, including its competitive position, the quality of its balance sheet and earnings, its future prospects, and the potential for growth and stock price appreciation. |
Prospectus 2020 | 225 |
226 | Prospectus 2020 |
Prospectus 2020 | 227 |
228 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Matthew A. Litfin, CFA | Director of Research (U.S.) and Senior Portfolio Manager at Columbia Wanger Asset Management, LLC, an investment advisory affiliate of Columbia Management Investment Advisers, LLC, and Portfolio Manager | Lead Portfolio Manager | 2018 | |||
Erika K. Maschmeyer, CFA | Senior Portfolio Manager at Columbia Wanger Asset Management, LLC, an investment advisory affiliate of Columbia Management Investment Advisers, LLC, and Portfolio Manager | Portfolio Manager | 2018 | |||
John L. Emerson, CFA | Senior Portfolio Manager at Columbia Wanger Asset Management, LLC, an investment advisory affiliate of Columbia Management Investment Advisers, LLC, and Portfolio Manager | Portfolio Manager | 2018 |
Prospectus 2020 | 229 |
■ | businesses that are believed to be fundamentally sound and undervalued due to investor indifference, investor misperception of company prospects, or other factors; |
■ | various measures of valuation, including price-to-cash flow, price-to-earnings, price-to-sales, and price-to-book value. The Investment Manager believes that companies with lower valuations are generally more likely to provide opportunities for capital appreciation; |
■ | a company’s current operating margins relative to its historic range and future potential; and/or |
■ | potential indicators of stock price appreciation, such as anticipated earnings growth, company restructuring, changes in management, business model changes, new product opportunities or anticipated improvements in macroeconomic factors. |
230 | Prospectus 2020 |
Prospectus 2020 | 231 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
232 | Prospectus 2020 |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
Prospectus 2020 | 233 |
234 | Prospectus 2020 |
Prospectus 2020 | 235 |
236 | Prospectus 2020 |
Prospectus 2020 | 237 |
238 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Fred Copper, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2018 | |||
Daisuke Nomoto, CMA (SAAJ) | Senior Portfolio Manager | Co-Portfolio Manager | 2018 |
Prospectus 2020 | 239 |
■ | a low price-to-earnings and/or low price-to-book ratio; |
■ | positive change in senior management; |
■ | positive corporate restructuring; |
■ | temporary setback in price due to factors that no longer exist or are ending; |
■ | a positive shift in the company’s business cycle; and/or |
■ | a catalyst for increase in the rate of the company’s earnings growth. |
240 | Prospectus 2020 |
Prospectus 2020 | 241 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Richard Rosen | Senior Portfolio Manager | Lead Portfolio Manager | 2008 | |||
Richard Taft | Senior Portfolio Manager | Portfolio Manager | 2016 |
242 | Prospectus 2020 |
■ | a low price-to-earnings and/or low price-to-book ratio; |
■ | positive change in senior management; |
■ | positive corporate restructuring; |
■ | temporary setback in price due to factors that no longer exist or are ending; |
■ | a positive shift in the company’s business cycle; and/or |
■ | a catalyst for increase in the rate of the company’s earnings growth. |
Prospectus 2020 | 243 |
244 | Prospectus 2020 |
Prospectus 2020 | 245 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Kari Montanus | Senior Portfolio Manager | Lead Portfolio Manager | 2018 | |||
Jonas Patrikson, CFA | Senior Portfolio Manager | Portfolio Manager | 2014 |
246 | Prospectus 2020 |
Prospectus 2020 | 247 |
■ | a low price-to-earnings and/or low price-to-book ratio; |
■ | positive change in senior management; |
■ | positive corporate restructuring; |
■ | temporary setback in price due to factors that no longer exist or are ending; |
■ | a positive shift in the company’s business cycle; and/or |
■ | a catalyst for increase in the rate of the company’s earnings growth. |
248 | Prospectus 2020 |
Prospectus 2020 | 249 |
250 | Prospectus 2020 |
Prospectus 2020 | 251 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Kari Montanus | Senior Portfolio Manager | Lead Portfolio Manager | 2014 | |||
Jonas Patrikson, CFA | Senior Portfolio Manager | Portfolio Manager | 2018 |
252 | Prospectus 2020 |
■ | Relative value within the U.S. Government mortgage sector. |
■ | The interest rate outlook. |
■ | The yield curve. |
■ | The interest rate or economic outlook changes. |
■ | The security is overvalued relative to alternative investments. |
■ | A more attractive opportunity exists. |
Prospectus 2020 | 253 |
254 | Prospectus 2020 |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
Prospectus 2020 | 255 |
256 | Prospectus 2020 |
Prospectus 2020 | 257 |
258 | Prospectus 2020 |
Prospectus 2020 | 259 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jason Callan | Senior Portfolio Manager and Head of Structured Assets | Co-Portfolio Manager | 2012 | |||
Tom Heuer, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2012 | |||
Ryan Osborn, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2019 |
260 | Prospectus 2020 |
Prospectus 2020 | 261 |
■ | Securities are purchased for the Fund when the management team determines that they have the potential for above average total return; |
■ | If a security falls below investment grade, the management team will decide whether to continue to hold the security. A security will be sold or its risks hedged if, in the opinion of the management team, the risk of continuing to hold the security is unattractive when compared to its total return potential; |
■ | Fund assets will be allocated among different countries and different market sectors (including different government or corporate issuers) and different maturities based on views of the relative value for each sector or maturity; |
■ | Duration and yield curve decisions will be based on fundamental views and quantitative analysis of forward looking interest rate determinants including inflation, real rates, risk premiums and relative supply/demand; |
■ | The Fund will target an average portfolio duration within a range of plus or minus 20% of the duration of the Index. The Subadvisers use an internal model for calculating duration, which may result in a different value for the duration of a benchmark compared to the duration calculated by the provider of the benchmark or another third party. |
262 | Prospectus 2020 |
Prospectus 2020 | 263 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A bond (or debt instrument) future is a derivative that is an agreement for the contract holder to buy or sell a bond or other debt instrument, a basket of bonds or other debt instrument, or the bonds or other debt instruments in an index on a specified date at a predetermined price. The buyer (long position) of a bond future is obliged to buy the underlying reference at the agreed price on expiry of the future. |
264 | Prospectus 2020 |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including LIBOR, swap rates, treasury rates and foreign interest rates. |
■ | An inflation rate swap is a derivative typically used to transfer inflation risk from one party to another through an exchange of cash flows. In an inflation rate swap, one party pays a fixed rate on a notional principal amount, while the other party pays a floating rate linked to an inflation index, such as the Consumer Price Index (CPI). |
Prospectus 2020 | 265 |
266 | Prospectus 2020 |
Prospectus 2020 | 267 |
268 | Prospectus 2020 |
Prospectus 2020 | 269 |
270 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Christopher Allen, CFA | Managing Director of BIL | Co-Portfolio Manager | 2018 | |||
Akiva Dickstein | Managing Director of BlackRock | Co-Portfolio Manager | 2018 | |||
Emanuella Enenajor | Director of BlackRock | Co-Portfolio Manager | May 2020 |
Prospectus 2020 | 271 |
272 | Prospectus 2020 |
Prospectus 2020 | 273 |
274 | Prospectus 2020 |
Prospectus 2020 | 275 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Gary Miller | Chief Investment Officer of Victory Capital’s Sycamore Capital | Lead Portfolio Manager | 2012 | |||
Jeffrey Graff, CFA | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 | |||
Gregory Conners | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 | |||
James Albers, CFA | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 | |||
Michael Rodarte, CFA | Portfolio Manager of Victory Capital’s Sycamore Capital | Portfolio Manager | 2012 |
276 | Prospectus 2020 |
■ | experienced and capable management; |
Prospectus 2020 | 277 |
■ | above-average earnings growth, cash flow growth, or profit margins; |
■ | leading or improving market position or proprietary advantages; |
■ | attractive business niche with the potential to sustain earnings momentum even during times of slow economic growth; |
■ | attractive valuation relative to a company’s peers or its own historical norm; |
■ | low stock price relative to a company’s underlying asset values; and/or |
■ | potential to conduct share repurchases. |
278 | Prospectus 2020 |
Prospectus 2020 | 279 |
280 | Prospectus 2020 |
Prospectus 2020 | 281 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Bruce Jacobs, Ph.D. | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | May 2019 | |||
Kenneth Levy, CFA | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | May 2019 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jeffrey Rottinghaus, CPA |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | May 2019 |
282 | Prospectus 2020 |
Prospectus 2020 | 283 |
■ | Undervalued relative to other companies in the same industry or market; |
■ | Good or improving fundamentals; and |
■ | An identifiable catalyst that could close the gap between market value and fair value over the next one to two years. |
284 | Prospectus 2020 |
Prospectus 2020 | 285 |
286 | Prospectus 2020 |
Prospectus 2020 | 287 |
288 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Bruce Jacobs, Ph.D. | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | 2017 | |||
Kenneth Levy, CFA | Co-Chief Investment Officer, Portfolio Manager and Co-Director of Research of Jacobs Levy | Co-Portfolio Manager | 2017 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Karen L. Bowie, CFA | Senior Vice President and Portfolio Manager of Nuveen Asset Management | Co-Portfolio Manager | 2017 |
Prospectus 2020 | 289 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Mark Dickherber, CFA, CPA | Principal, Director of Small Cap Strategies of SBH | Co-Portfolio Manager | 2014 | |||
Shaun Nicholson | Principal, Senior Portfolio Manager of SBH | Co-Portfolio Manager | 2014 |
290 | Prospectus 2020 |
Prospectus 2020 | 291 |
292 | Prospectus 2020 |
Prospectus 2020 | 293 |
294 | Prospectus 2020 |
Class 1 | Class 2 | Class 3 | |
Columbia VP - Disciplined Core Fund | 0.69% | 0.94% | 0.815% |
Columbia VP - Global Strategic Income Fund | 0.61% | 0.86% | 0.735% |
Columbia VP - Government Money Market Fund | 0.45% | 0.70% | 0.575% |
Columbia VP - High Yield Bond Fund | 0.67% | 0.92% | 0.795% |
Columbia VP - Income Opportunities Fund | 0.67% | 0.92% | 0.795% |
Columbia VP - Intermediate Bond Fund | 0.55% | 0.80% | 0.675% |
Columbia VP - Mid Cap Growth Fund | 0.79% | 1.04% | 0.915% |
Columbia VP - Select Large Cap Value Fund | 0.72% | 0.97% | 0.845% |
Columbia VP - Select Mid Cap Value Fund | 0.81% | 1.06% | 0.935% |
Columbia VP - Select Small Cap Value Fund | 0.85% | 1.10% | 0.975% |
CTIVP® - BlackRock Global Inflation-Protected Securities Fund | 0.65% | 0.90% | 0.775% |
CTIVP® - Victory Sycamore Established Value Fund | 0.85% | 1.10% | 0.975% |
VP - Partners Core Equity Fund | 0.69% | 0.94% | 0.815% |
VP - Partners Small Cap Value Fund | 0.88% | 1.13% | 1.005% |
Class 1 | Class 2 | Class 3 | |
Columbia VP - Balanced Fund | 0.77% | 1.02% | 0.895% |
Columbia VP - Dividend Opportunity Fund | 0.73% | 0.98% | 0.855% |
Columbia VP - Emerging Markets Fund | 1.14% | 1.39% | 1.265% |
Columbia VP - Large Cap Growth Fund | 0.75% | 1.00% | 0.875% |
Columbia VP - Large Cap Index Fund | 0.29% | 0.54% | 0.415% |
Columbia VP - Overseas Core Fund | 0.90% | 1.15% | 1.025% |
Columbia VP - U.S. Government Mortgage Fund | 0.58% | 0.83% | 0.705% |
Prospectus 2020 | 295 |
296 | Prospectus 2020 |
Management fee for the fiscal year ended December 31, 2019 | |
Columbia VP - Balanced Fund | 0.69% |
Columbia VP - Disciplined Core Fund | 0.63% |
Columbia VP - Dividend Opportunity Fund | 0.67% |
Columbia VP - Emerging Markets Fund | 1.10% |
Columbia VP - Global Strategic Income Fund | 0.65% |
Columbia VP - Government Money Market Fund | 0.39% |
Columbia VP - High Yield Bond Fund | 0.66% |
Columbia VP - Income Opportunities Fund | 0.66% |
Columbia VP - Intermediate Bond Fund | 0.47%* |
Columbia VP - Large Cap Growth Fund | 0.70% |
Columbia VP - Large Cap Index Fund | 0.20% |
Columbia VP - Mid Cap Growth Fund | 0.82% |
Columbia VP - Overseas Core Fund | 0.83% |
Columbia VP - Select Large Cap Value Fund | 0.71% |
Columbia VP - Select Mid Cap Value Fund | 0.82% |
Columbia VP - Select Small Cap Value Fund | 0.87% |
Columbia VP - U.S. Government Mortgage Fund | 0.43% |
CTIVP® - BlackRock Global Inflation-Protected Securities Fund | 0.51% |
CTIVP® - Victory Sycamore Established Value Fund | 0.76% |
VP - Partners Core Equity Fund | 0.69% |
VP - Partners Small Cap Value Fund | 0.85% |
Prospectus 2020 | 297 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
298 | Prospectus 2020 |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
Prospectus 2020 | 299 |
Class 1 Shares | Class 2 Shares | Class 3 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | ||
Investment Limits | none | none | none |
Conversion Features | none | none | none |
Front-End Sales Charges | none | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% | 0.125% |
300 | Prospectus 2020 |
Prospectus 2020 | 301 |
302 | Prospectus 2020 |
Prospectus 2020 | 303 |
304 | Prospectus 2020 |
Prospectus 2020 | 305 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
306 | Prospectus 2020 |
Prospectus 2020 | 307 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. |
Declarations | Distributions | |
Columbia VP – Emerging Markets Fund | Quarterly | Quarterly |
Columbia VP – Global Strategic Income Fund | Quarterly | Quarterly |
Columbia VP – Government Money Market Fund | Daily | Quarterly |
Columbia VP – High Yield Bond Fund | Annually | Annually |
Columbia VP – Income Opportunities Fund | Annually | Annually |
Columbia VP – Intermediate Bond Fund | Annually | Annually |
Columbia VP – Overseas Core Fund | Quarterly | Quarterly |
Columbia VP – U.S. Government Mortgage Fund | Annually | Annually |
CTIVP® – BlackRock Global Inflation-Protected Securities Fund | Annually | Annually |
308 | Prospectus 2020 |
Prospectus 2020 | 309 |
310 | Prospectus 2020 |
Prospectus 2020 | 311 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $25.35 | 0.48 | 5.34 | 5.82 |
Year Ended 12/31/2018 | $26.90 | 0.42 | (1.97) | (1.55) |
Year Ended 12/31/2017 | $23.46 | 0.34 | 3.10 | 3.44 |
Year Ended 12/31/2016 | $22.00 | 0.33 | 1.13 | 1.46 |
Year Ended 12/31/2015 | $21.59 | 0.59(c) | (0.18) | 0.41 |
Class 2 | ||||
Year Ended 12/31/2019 | $25.06 | 0.41 | 5.27 | 5.68 |
Year Ended 12/31/2018 | $26.66 | 0.34 | (1.94) | (1.60) |
Year Ended 12/31/2017 | $23.30 | 0.28 | 3.08 | 3.36 |
Year Ended 12/31/2016 | $21.91 | 0.27 | 1.12 | 1.39 |
Year Ended 12/31/2015 | $21.56 | 0.53(c) | (0.18) | 0.35 |
Class 3 | ||||
Year Ended 12/31/2019 | $25.24 | 0.45 | 5.30 | 5.75 |
Year Ended 12/31/2018 | $26.82 | 0.38 | (1.96) | (1.58) |
Year Ended 12/31/2017 | $23.42 | 0.30 | 3.10 | 3.40 |
Year Ended 12/31/2016 | $22.01 | 0.29 | 1.12 | 1.41 |
Year Ended 12/31/2015 | $21.64 | 0.55(c) | (0.18) | 0.37 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.33 per share. |
312 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $31.17 | 22.96% | 0.79% | 0.76% | 1.63% | 126% | $741 |
Year Ended 12/31/2018 | $25.35 | (5.76%) | 0.78% | 0.75% | 1.53% | 81% | $3 |
Year Ended 12/31/2017 | $26.90 | 14.66% | 0.77% | 0.74% | 1.36% | 63% | $3 |
Year Ended 12/31/2016 | $23.46 | 6.64% | 0.79% | 0.79% | 1.40% | 65% | $3 |
Year Ended 12/31/2015 | $22.00 | 1.90% | 0.76% | 0.76% | 2.69% | 89% | $3 |
Class 2 | |||||||
Year Ended 12/31/2019 | $30.74 | 22.66% | 1.03% | 1.01% | 1.43% | 126% | $4 |
Year Ended 12/31/2018 | $25.06 | (6.00%) | 1.03% | 1.00% | 1.27% | 81% | $3 |
Year Ended 12/31/2017 | $26.66 | 14.42% | 1.02% | 0.99% | 1.11% | 63% | $3 |
Year Ended 12/31/2016 | $23.30 | 6.34% | 1.04% | 1.04% | 1.16% | 65% | $3 |
Year Ended 12/31/2015 | $21.91 | 1.62% | 1.01% | 1.01% | 2.43% | 89% | $3 |
Class 3 | |||||||
Year Ended 12/31/2019 | $30.99 | 22.78% | 0.91% | 0.88% | 1.57% | 126% | $1,137,620 |
Year Ended 12/31/2018 | $25.24 | (5.89%) | 0.91% | 0.87% | 1.40% | 81% | $1,004,017 |
Year Ended 12/31/2017 | $26.82 | 14.52% | 0.91% | 0.89% | 1.20% | 63% | $1,165,032 |
Year Ended 12/31/2016 | $23.42 | 6.41% | 0.91% | 0.91% | 1.27% | 65% | $1,059,420 |
Year Ended 12/31/2015 | $22.01 | 1.71% | 0.94% | 0.92% | 2.51% | 89% | $964,446 |
Prospectus 2020 | 313 |
Prospectus 2020 | 315 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $46.89 | 0.76 | 10.86 | 11.62 |
Year Ended 12/31/2018 | $48.64 | 0.72 | (2.47) | (1.75) |
Year Ended 12/31/2017 | $39.11 | 0.77 | 8.76 | 9.53 |
Year Ended 12/31/2016 | $36.19 | 0.62 | 2.30 | 2.92 |
Year Ended 12/31/2015 | $35.87 | 0.57 | (0.25) | 0.32 |
Class 2 | ||||
Year Ended 12/31/2019 | $45.90 | 0.61 | 10.62 | 11.23 |
Year Ended 12/31/2018 | $47.74 | 0.60 | (2.44) | (1.84) |
Year Ended 12/31/2017 | $38.48 | 0.65 | 8.61 | 9.26 |
Year Ended 12/31/2016 | $35.69 | 0.52 | 2.27 | 2.79 |
Year Ended 12/31/2015 | $35.47 | 0.47 | (0.25) | 0.22 |
Class 3 | ||||
Year Ended 12/31/2019 | $46.36 | 0.68 | 10.74 | 11.42 |
Year Ended 12/31/2018 | $48.16 | 0.65 | (2.45) | (1.80) |
Year Ended 12/31/2017 | $38.77 | 0.71 | 8.68 | 9.39 |
Year Ended 12/31/2016 | $35.92 | 0.57 | 2.28 | 2.85 |
Year Ended 12/31/2015 | $35.65 | 0.52 | (0.25) | 0.27 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
316 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $58.51 | 24.78% | 0.66% | 0.66% | 1.41% | 69% | $4,290,429 |
Year Ended 12/31/2018 | $46.89 | (3.60%) | 0.66% | 0.66% | 1.42% | 74% | $3,650,498 |
Year Ended 12/31/2017 | $48.64 | 24.37% | 0.68% | 0.68% | 1.79% | 69% | $4,219,124 |
Year Ended 12/31/2016 | $39.11 | 8.07% | 0.71% | 0.71% | 1.70% | 80% | $3,583,512 |
Year Ended 12/31/2015 | $36.19 | 0.89% | 0.73% | 0.73% | 1.58% | 78% | $2,941,017 |
Class 2 | |||||||
Year Ended 12/31/2019 | $57.13 | 24.46% | 0.91% | 0.91% | 1.17% | 69% | $39,356 |
Year Ended 12/31/2018 | $45.90 | (3.85%) | 0.91% | 0.91% | 1.21% | 74% | $28,322 |
Year Ended 12/31/2017 | $47.74 | 24.07% | 0.93% | 0.93% | 1.54% | 69% | $23,671 |
Year Ended 12/31/2016 | $38.48 | 7.82% | 0.96% | 0.96% | 1.45% | 80% | $18,402 |
Year Ended 12/31/2015 | $35.69 | 0.62% | 0.98% | 0.98% | 1.31% | 78% | $16,917 |
Class 3 | |||||||
Year Ended 12/31/2019 | $57.78 | 24.63% | 0.78% | 0.78% | 1.29% | 69% | $1,260,116 |
Year Ended 12/31/2018 | $46.36 | (3.74%) | 0.78% | 0.78% | 1.29% | 74% | $1,139,339 |
Year Ended 12/31/2017 | $48.16 | 24.22% | 0.81% | 0.81% | 1.67% | 69% | $1,328,984 |
Year Ended 12/31/2016 | $38.77 | 7.94% | 0.83% | 0.83% | 1.58% | 80% | $1,214,003 |
Year Ended 12/31/2015 | $35.92 | 0.76% | 0.85% | 0.85% | 1.44% | 78% | $1,280,983 |
Prospectus 2020 | 317 |
Prospectus 2020 | 319 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $23.85 | 0.85 | 4.89 | 5.74 |
Year Ended 12/31/2018 | $25.30 | 0.85 | (2.30) | (1.45) |
Year Ended 12/31/2017 | $22.12 | 0.89 | 2.29 | 3.18 |
Year Ended 12/31/2016 | $19.46 | 0.78 | 1.88 | 2.66 |
Year Ended 12/31/2015 | $19.99 | 0.73 | (1.26) | (0.53) |
Class 2 | ||||
Year Ended 12/31/2019 | $23.32 | 0.77 | 4.77 | 5.54 |
Year Ended 12/31/2018 | $24.81 | 0.75 | (2.24) | (1.49) |
Year Ended 12/31/2017 | $21.74 | 0.82 | 2.25 | 3.07 |
Year Ended 12/31/2016 | $19.17 | 0.72 | 1.85 | 2.57 |
Year Ended 12/31/2015 | $19.74 | 0.65 | (1.22) | (0.57) |
Class 3 | ||||
Year Ended 12/31/2019 | $23.58 | 0.81 | 4.83 | 5.64 |
Year Ended 12/31/2018 | $25.05 | 0.79 | (2.26) | (1.47) |
Year Ended 12/31/2017 | $21.92 | 0.86 | 2.27 | 3.13 |
Year Ended 12/31/2016 | $19.31 | 0.75 | 1.86 | 2.61 |
Year Ended 12/31/2015 | $19.86 | 0.68 | (1.23) | (0.55) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
320 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $29.59 | 24.07% | 0.74% | 0.72% | 3.13% | 46% | $632,898 |
Year Ended 12/31/2018 | $23.85 | (5.73%) | 0.72% | 0.72% | 3.31% | 87% | $537,062 |
Year Ended 12/31/2017 | $25.30 | 14.38% | 0.73% | 0.73% | 3.82% | 62% | $832,599 |
Year Ended 12/31/2016 | $22.12 | 13.67% | 0.74% | 0.74% | 3.78% | 64% | $742,337 |
Year Ended 12/31/2015 | $19.46 | (2.65%) | 0.71% | 0.71% | 3.65% | 93% | $657,752 |
Class 2 | |||||||
Year Ended 12/31/2019 | $28.86 | 23.76% | 0.99% | 0.97% | 2.88% | 46% | $81,504 |
Year Ended 12/31/2018 | $23.32 | (6.01%) | 0.97% | 0.97% | 2.99% | 87% | $61,764 |
Year Ended 12/31/2017 | $24.81 | 14.12% | 0.98% | 0.98% | 3.58% | 62% | $69,367 |
Year Ended 12/31/2016 | $21.74 | 13.41% | 0.99% | 0.99% | 3.52% | 64% | $59,186 |
Year Ended 12/31/2015 | $19.17 | (2.89%) | 0.98% | 0.98% | 3.33% | 93% | $46,304 |
Class 3 | |||||||
Year Ended 12/31/2019 | $29.22 | 23.92% | 0.86% | 0.84% | 3.00% | 46% | $810,575 |
Year Ended 12/31/2018 | $23.58 | (5.87%) | 0.85% | 0.84% | 3.11% | 87% | $749,273 |
Year Ended 12/31/2017 | $25.05 | 14.28% | 0.86% | 0.86% | 3.71% | 62% | $939,770 |
Year Ended 12/31/2016 | $21.92 | 13.52% | 0.87% | 0.87% | 3.66% | 64% | $967,557 |
Year Ended 12/31/2015 | $19.31 | (2.77%) | 0.86% | 0.86% | 3.45% | 93% | $982,852 |
Prospectus 2020 | 321 |
Prospectus 2020 | 323 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $16.38 | 0.09 | 4.79 | 4.88 | (0.04) | (2.25) | (2.29) |
Year Ended 12/31/2018 | $21.04 | 0.14 | (4.67) | (4.53) | (0.13) | — | (0.13) |
Year Ended 12/31/2017 | $14.29 | 0.05 | 6.73 | 6.78 | (0.03) | — | (0.03) |
Year Ended 12/31/2016 | $13.61 | 0.03 | 0.67 | 0.70 | (0.02) | — | (0.02) |
Year Ended 12/31/2015 | $15.36 | 0.06 | (1.37) | (1.31) | (0.02) | (0.42) | (0.44) |
Class 2 | |||||||
Year Ended 12/31/2019 | $16.26 | 0.06 | 4.73 | 4.79 | (0.02) | (2.25) | (2.27) |
Year Ended 12/31/2018 | $20.84 | 0.06 | (4.59) | (4.53) | (0.05) | — | (0.05) |
Year Ended 12/31/2017 | $14.17 | 0.01 | 6.66 | 6.67 | (0.00) (f) | — | (0.00) (f) |
Year Ended 12/31/2016 | $13.53 | 0.02 | 0.63 | 0.65 | (0.01) | — | (0.01) |
Year Ended 12/31/2015 | $15.30 | 0.03 | (1.37) | (1.34) | (0.01) | (0.42) | (0.43) |
Class 3 | |||||||
Year Ended 12/31/2019 | $16.33 | 0.08 | 4.76 | 4.84 | (0.03) | (2.25) | (2.28) |
Year Ended 12/31/2018 | $20.96 | 0.09 | (4.63) | (4.54) | (0.09) | — | (0.09) |
Year Ended 12/31/2017 | $14.24 | 0.03 | 6.71 | 6.74 | (0.02) | — | (0.02) |
Year Ended 12/31/2016 | $13.58 | 0.04 | 0.63 | 0.67 | (0.01) | — | (0.01) |
Year Ended 12/31/2015 | $15.34 | 0.04 | (1.36) | (1.32) | (0.02) | (0.42) | (0.44) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | The Fund received a payment from an affiliate. Had the Fund not received this payment, the total return would have been lower by 0.04%. |
(d) | Ratios include interfund lending expense which is less than 0.01%. |
(e) | Ratios include line of credit interest expense which is less than 0.01%. |
(f) | Rounds to zero. |
(g) | The Fund received a payment from an affiliate which had an impact of less than 0.01%. |
324 | Prospectus 2020 |
Reimbursement
from affiliate |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | ||||||||
Year Ended 12/31/2019 | 0.01 | $18.98 | 31.50% (c) | 1.22% (d) | 1.17% (d) | 0.53% | 26% | $133,990 |
Year Ended 12/31/2018 | — | $16.38 | (21.62%) | 1.20% (d) | 1.20% (d) | 0.70% | 41% | $196,720 |
Year Ended 12/31/2017 | — | $21.04 | 47.51% | 1.25% (e) | 1.24% (e) | 0.31% | 43% | $457,065 |
Year Ended 12/31/2016 | — | $14.29 | 5.13% | 1.29% (e) | 1.27% (e) | 0.25% | 74% | $408,360 |
Year Ended 12/31/2015 | — | $13.61 | (8.83%) | 1.28% | 1.25% | 0.40% | 77% | $974,542 |
Class 2 | ||||||||
Year Ended 12/31/2019 | 0.00(f) | $18.78 | 31.13% (g) | 1.47% (d) | 1.42% (d) | 0.33% | 26% | $55,859 |
Year Ended 12/31/2018 | — | $16.26 | (21.78%) | 1.47% (d) | 1.46% (d) | 0.33% | 41% | $42,531 |
Year Ended 12/31/2017 | — | $20.84 | 47.10% | 1.50% (e) | 1.48% (e) | 0.04% | 43% | $46,421 |
Year Ended 12/31/2016 | — | $14.17 | 4.81% | 1.54% (e) | 1.52% (e) | 0.14% | 74% | $21,331 |
Year Ended 12/31/2015 | — | $13.53 | (9.06%) | 1.53% | 1.50% | 0.17% | 77% | $18,561 |
Class 3 | ||||||||
Year Ended 12/31/2019 | 0.00(f) | $18.89 | 31.29% (g) | 1.34% (d) | 1.29% (d) | 0.45% | 26% | $196,505 |
Year Ended 12/31/2018 | — | $16.33 | (21.73%) | 1.34% (d) | 1.33% (d) | 0.44% | 41% | $173,529 |
Year Ended 12/31/2017 | — | $20.96 | 47.34% | 1.37% (e) | 1.36% (e) | 0.18% | 43% | $244,408 |
Year Ended 12/31/2016 | — | $14.24 | 4.97% | 1.42% (e) | 1.40% (e) | 0.26% | 74% | $183,897 |
Year Ended 12/31/2015 | — | $13.58 | (8.94%) | 1.40% | 1.38% | 0.28% | 77% | $207,067 |
Prospectus 2020 | 325 |
Prospectus 2020 | 327 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Increase
from payment by affiliate |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | ||||||||
Year Ended 12/31/2019 | $8.21 | 0.29 | 0.61 | 0.00(c) | 0.90 | — | — | — |
Year Ended 12/31/2018 | $9.03 | 0.29 | (0.74) | — | (0.45) | (0.37) | — | (0.37) |
Year Ended 12/31/2017 | $8.53 | 0.29 | 0.21 | — | 0.50 | — | — | — |
Year Ended 12/31/2016 | $8.85 | 0.29 | (0.36) | — | (0.07) | — | (0.25) | (0.25) |
Year Ended 12/31/2015 | $10.26 | 0.30 | (0.87) | — | (0.57) | — | (0.84) | (0.84) |
Class 2 | ||||||||
Year Ended 12/31/2019 | $8.09 | 0.26 | 0.61 | 0.00(c) | 0.87 | — | — | — |
Year Ended 12/31/2018 | $8.91 | 0.26 | (0.73) | — | (0.47) | (0.35) | — | (0.35) |
Year Ended 12/31/2017 | $8.43 | 0.27 | 0.21 | — | 0.48 | — | — | — |
Year Ended 12/31/2016 | $8.78 | 0.26 | (0.36) | — | (0.10) | — | (0.25) | (0.25) |
Year Ended 12/31/2015 | $10.20 | 0.32 | (0.90) | — | (0.58) | — | (0.84) | (0.84) |
Class 3 | ||||||||
Year Ended 12/31/2019 | $8.16 | 0.27 | 0.62 | 0.00(c) | 0.89 | — | — | — |
Year Ended 12/31/2018 | $8.98 | 0.28 | (0.74) | — | (0.46) | (0.36) | — | (0.36) |
Year Ended 12/31/2017 | $8.49 | 0.28 | 0.21 | — | 0.49 | — | — | — |
Year Ended 12/31/2016 | $8.83 | 0.27 | (0.36) | — | (0.09) | — | (0.25) | (0.25) |
Year Ended 12/31/2015 | $10.25 | 0.33 | (0.91) | — | (0.58) | — | (0.84) | (0.84) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
(d) | The Fund received a payment from an affiliate. Had the Fund not received this payment, the total return would have been lower by 0.01%. |
(e) | Ratios include interest on collateral expense which is less than 0.01%. |
328 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.11 | 10.96% (d) | 0.87% | 0.59% | 3.27% | 57% | $10 |
Year Ended 12/31/2018 | $8.21 | (5.20%) | 0.86% (e) | 0.64% (e) | 3.34% | 86% | $9 |
Year Ended 12/31/2017 | $9.03 | 5.86% | 0.85% | 0.68% | 3.33% | 37% | $10 |
Year Ended 12/31/2016 | $8.53 | (1.00%) | 0.79% | 0.70% | 3.17% | 162% | $9 |
Year Ended 12/31/2015 | $8.85 | (6.08%) | 0.75% | 0.75% | 2.88% | 109% | $9 |
Class 2 | |||||||
Year Ended 12/31/2019 | $8.96 | 10.75% (d) | 1.12% | 0.84% | 3.01% | 57% | $10,750 |
Year Ended 12/31/2018 | $8.09 | (5.51%) | 1.10% (e) | 0.89% (e) | 3.08% | 86% | $9,512 |
Year Ended 12/31/2017 | $8.91 | 5.69% | 1.10% | 0.93% | 3.07% | 37% | $9,719 |
Year Ended 12/31/2016 | $8.43 | (1.35%) | 1.05% | 0.95% | 2.92% | 162% | $8,812 |
Year Ended 12/31/2015 | $8.78 | (6.22%) | 1.04% | 0.98% | 3.30% | 109% | $9,004 |
Class 3 | |||||||
Year Ended 12/31/2019 | $9.05 | 10.91% (d) | 1.00% | 0.72% | 3.14% | 57% | $102,668 |
Year Ended 12/31/2018 | $8.16 | (5.34%) | 0.97% (e) | 0.76% (e) | 3.25% | 86% | $104,256 |
Year Ended 12/31/2017 | $8.98 | 5.77% | 0.98% | 0.80% | 3.18% | 37% | $131,599 |
Year Ended 12/31/2016 | $8.49 | (1.23%) | 0.92% | 0.83% | 3.03% | 162% | $146,851 |
Year Ended 12/31/2015 | $8.83 | (6.17%) | 0.91% | 0.86% | 3.42% | 109% | $179,329 |
Prospectus 2020 | 329 |
Prospectus 2020 | 331 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $1.00 | 0.02 | 0.00(b) | 0.02 | (0.02) | (0.00) (b) | (0.02) |
Year Ended 12/31/2018 | $1.00 | 0.02 | 0.00(b) | 0.02 | (0.02) | — | (0.02) |
Year Ended 12/31/2017 | $1.00 | 0.00(b) | 0.00 | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Year Ended 12/31/2016 | $1.00 | 0.00(b) | 0.00(b) | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Year Ended 12/31/2015 | $1.00 | 0.00(b) | 0.00(b) | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Class 2 | |||||||
Year Ended 12/31/2019 | $1.00 | 0.02 | 0.00(b) | 0.02 | (0.02) | (0.00) (b) | (0.02) |
Year Ended 12/31/2018 | $1.00 | 0.01 | 0.00(b) | 0.01 | (0.01) | — | (0.01) |
Year Ended 12/31/2017 | $1.00 | 0.00(b) | 0.00 | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Year Ended 12/31/2016 | $1.00 | 0.00(b) | 0.00(b) | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Year Ended 12/31/2015 | $1.00 | 0.00(b) | 0.00(b) | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Class 3 | |||||||
Year Ended 12/31/2019 | $1.00 | 0.02 | 0.00(b) | 0.02 | (0.02) | (0.00) (b) | (0.02) |
Year Ended 12/31/2018 | $1.00 | 0.01 | 0.00(b) | 0.01 | (0.01) | — | (0.01) |
Year Ended 12/31/2017 | $1.00 | 0.00(b) | 0.00 | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Year Ended 12/31/2016 | $1.00 | 0.00(b) | 0.00(b) | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Year Ended 12/31/2015 | $1.00 | 0.00(b) | 0.00(b) | 0.00(b) | (0.00) (b) | — | (0.00) (b) |
Notes to Financial Highlights | |
(a) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(b) | Rounds to zero. |
332 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets |
Total net
expense ratio to average net assets(a) |
Net investment
income ratio to average net assets |
Net
assets, end of period (000's) |
|
Class 1 | ||||||
Year Ended 12/31/2019 | $1.00 | 1.89% | 0.47% | 0.36% | 1.87% | $86,841 |
Year Ended 12/31/2018 | $1.00 | 1.51% | 0.46% | 0.32% | 1.77% | $301,167 |
Year Ended 12/31/2017 | $1.00 | 0.43% | 0.50% | 0.45% | 0.42% | $44,578 |
Year Ended 12/31/2016 | $1.00 | 0.01% | 0.49% | 0.36% | 0.01% | $48,310 |
Year Ended 12/31/2015 | $1.00 | 0.01% | 0.49% | 0.13% | 0.01% | $149,749 |
Class 2 | ||||||
Year Ended 12/31/2019 | $1.00 | 1.64% | 0.72% | 0.62% | 1.60% | $61,083 |
Year Ended 12/31/2018 | $1.00 | 1.26% | 0.72% | 0.59% | 1.36% | $67,341 |
Year Ended 12/31/2017 | $1.00 | 0.18% | 0.75% | 0.70% | 0.17% | $32,860 |
Year Ended 12/31/2016 | $1.00 | 0.01% | 0.74% | 0.36% | 0.01% | $35,914 |
Year Ended 12/31/2015 | $1.00 | 0.01% | 0.75% | 0.13% | 0.01% | $29,276 |
Class 3 | ||||||
Year Ended 12/31/2019 | $1.00 | 1.77% | 0.60% | 0.49% | 1.72% | $181,970 |
Year Ended 12/31/2018 | $1.00 | 1.38% | 0.60% | 0.48% | 1.36% | $209,931 |
Year Ended 12/31/2017 | $1.00 | 0.30% | 0.62% | 0.57% | 0.29% | $224,799 |
Year Ended 12/31/2016 | $1.00 | 0.01% | 0.62% | 0.36% | 0.01% | $269,488 |
Year Ended 12/31/2015 | $1.00 | 0.01% | 0.62% | 0.13% | 0.01% | $266,420 |
Prospectus 2020 | 333 |
Prospectus 2020 | 335 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Total
distributions to shareholders |
|
Class 1 | ||||||
Year Ended 12/31/2019 | $6.20 | 0.34 | 0.70 | 1.04 | (0.41) | (0.41) |
Year Ended 12/31/2018 | $6.84 | 0.35 | (0.60) | (0.25) | (0.39) | (0.39) |
Year Ended 12/31/2017 | $6.79 | 0.36 | 0.08 | 0.44 | (0.39) | (0.39) |
Year Ended 12/31/2016 | $6.46 | 0.35 | 0.40 | 0.75 | (0.42) | (0.42) |
Year Ended 12/31/2015 | $6.96 | 0.36 | (0.42) | (0.06) | (0.44) | (0.44) |
Class 2 | ||||||
Year Ended 12/31/2019 | $6.15 | 0.33 | 0.67 | 1.00 | (0.39) | (0.39) |
Year Ended 12/31/2018 | $6.78 | 0.33 | (0.59) | (0.26) | (0.37) | (0.37) |
Year Ended 12/31/2017 | $6.74 | 0.32 | 0.09 | 0.41 | (0.37) | (0.37) |
Year Ended 12/31/2016 | $6.41 | 0.34 | 0.39 | 0.73 | (0.40) | (0.40) |
Year Ended 12/31/2015 | $6.91 | 0.35 | (0.43) | (0.08) | (0.42) | (0.42) |
Class 3 | ||||||
Year Ended 12/31/2019 | $6.19 | 0.34 | 0.68 | 1.02 | (0.40) | (0.40) |
Year Ended 12/31/2018 | $6.83 | 0.34 | (0.60) | (0.26) | (0.38) | (0.38) |
Year Ended 12/31/2017 | $6.78 | 0.34 | 0.09 | 0.43 | (0.38) | (0.38) |
Year Ended 12/31/2016 | $6.45 | 0.35 | 0.39 | 0.74 | (0.41) | (0.41) |
Year Ended 12/31/2015 | $6.94 | 0.36 | (0.42) | (0.06) | (0.43) | (0.43) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
336 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $6.83 | 17.00% | 0.80% | 0.67% | 5.21% | 49% | $227 |
Year Ended 12/31/2018 | $6.20 | (3.86%) | 0.77% | 0.73% | 5.31% | 39% | $11 |
Year Ended 12/31/2017 | $6.84 | 6.53% | 0.75% | 0.75% | 5.12% | 51% | $12 |
Year Ended 12/31/2016 | $6.79 | 11.84% | 0.75% | 0.75% | 5.32% | 51% | $3,135 |
Year Ended 12/31/2015 | $6.46 | (1.15%) | 0.78% | 0.75% | 5.35% | 47% | $1,934 |
Class 2 | |||||||
Year Ended 12/31/2019 | $6.76 | 16.52% | 1.02% | 0.94% | 5.04% | 49% | $74,825 |
Year Ended 12/31/2018 | $6.15 | (4.00%) | 1.01% | 0.98% | 5.06% | 39% | $54,532 |
Year Ended 12/31/2017 | $6.78 | 6.17% | 1.01% | 1.01% | 4.76% | 51% | $59,098 |
Year Ended 12/31/2016 | $6.74 | 11.65% | 1.00% | 1.00% | 5.07% | 51% | $48,310 |
Year Ended 12/31/2015 | $6.41 | (1.41%) | 1.02% | 1.00% | 5.06% | 47% | $38,807 |
Class 3 | |||||||
Year Ended 12/31/2019 | $6.81 | 16.72% | 0.89% | 0.81% | 5.18% | 49% | $280,814 |
Year Ended 12/31/2018 | $6.19 | (4.00%) | 0.89% | 0.86% | 5.18% | 39% | $279,157 |
Year Ended 12/31/2017 | $6.83 | 6.41% | 0.89% | 0.89% | 4.89% | 51% | $364,733 |
Year Ended 12/31/2016 | $6.78 | 11.72% | 0.88% | 0.88% | 5.20% | 51% | $400,844 |
Year Ended 12/31/2015 | $6.45 | (1.14%) | 0.90% | 0.87% | 5.17% | 47% | $420,576 |
Prospectus 2020 | 337 |
Prospectus 2020 | 339 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $6.91 | 0.36 | 0.76 | 1.12 | (0.39) | — | (0.39) |
Year Ended 12/31/2018 | $7.56 | 0.37 | (0.65) | (0.28) | (0.37) | — | (0.37) |
Year Ended 12/31/2017 | $7.56 | 0.35 | 0.14 | 0.49 | (0.49) | — | (0.49) |
Year Ended 12/31/2016 | $8.07 | 0.40 | 0.41 | 0.81 | (0.93) | (0.39) | (1.32) |
Year Ended 12/31/2015 | $9.06 | 0.43 | (0.49) | (0.06) | (0.85) | (0.08) | (0.93) |
Class 2 | |||||||
Year Ended 12/31/2019 | $6.87 | 0.34 | 0.75 | 1.09 | (0.37) | — | (0.37) |
Year Ended 12/31/2018 | $7.51 | 0.35 | (0.64) | (0.29) | (0.35) | — | (0.35) |
Year Ended 12/31/2017 | $7.52 | 0.33 | 0.13 | 0.46 | (0.47) | — | (0.47) |
Year Ended 12/31/2016 | $8.02 | 0.38 | 0.42 | 0.80 | (0.91) | (0.39) | (1.30) |
Year Ended 12/31/2015 | $9.01 | 0.40 | (0.47) | (0.07) | (0.84) | (0.08) | (0.92) |
Class 3 | |||||||
Year Ended 12/31/2019 | $6.95 | 0.35 | 0.76 | 1.11 | (0.38) | — | (0.38) |
Year Ended 12/31/2018 | $7.60 | 0.36 | (0.65) | (0.29) | (0.36) | — | (0.36) |
Year Ended 12/31/2017 | $7.60 | 0.35 | 0.13 | 0.48 | (0.48) | — | (0.48) |
Year Ended 12/31/2016 | $8.10 | 0.38 | 0.43 | 0.81 | (0.92) | (0.39) | (1.31) |
Year Ended 12/31/2015 | $9.08 | 0.42 | (0.48) | (0.06) | (0.84) | (0.08) | (0.92) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
340 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $7.64 | 16.47% | 0.75% | 0.69% | 4.83% | 58% | $178,149 |
Year Ended 12/31/2018 | $6.91 | (3.75%) | 0.74% | 0.73% | 5.05% | 42% | $138,357 |
Year Ended 12/31/2017 | $7.56 | 6.56% | 0.76% | 0.76% | 4.66% | 50% | $132,262 |
Year Ended 12/31/2016 | $7.56 | 10.93% | 0.74% | 0.74% | 4.99% | 48% | $112,544 |
Year Ended 12/31/2015 | $8.07 | (1.00%) | 0.73% | 0.72% | 4.85% | 52% | $328,741 |
Class 2 | |||||||
Year Ended 12/31/2019 | $7.59 | 16.12% | 1.00% | 0.94% | 4.59% | 58% | $37,916 |
Year Ended 12/31/2018 | $6.87 | (3.90%) | 0.99% | 0.98% | 4.79% | 42% | $32,893 |
Year Ended 12/31/2017 | $7.51 | 6.20% | 1.01% | 1.01% | 4.41% | 50% | $36,579 |
Year Ended 12/31/2016 | $7.52 | 10.80% | 0.98% | 0.98% | 4.72% | 48% | $33,095 |
Year Ended 12/31/2015 | $8.02 | (1.21%) | 0.99% | 0.98% | 4.62% | 52% | $111,563 |
Class 3 | |||||||
Year Ended 12/31/2019 | $7.68 | 16.23% | 0.87% | 0.81% | 4.72% | 58% | $147,395 |
Year Ended 12/31/2018 | $6.95 | (3.86%) | 0.87% | 0.85% | 4.90% | 42% | $146,078 |
Year Ended 12/31/2017 | $7.60 | 6.39% | 0.88% | 0.88% | 4.55% | 50% | $199,852 |
Year Ended 12/31/2016 | $7.60 | 10.86% | 0.87% | 0.87% | 4.86% | 48% | $224,303 |
Year Ended 12/31/2015 | $8.10 | (1.02%) | 0.86% | 0.85% | 4.74% | 52% | $154,637 |
Prospectus 2020 | 341 |
Prospectus 2020 | 343 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.08 | 0.36 | 0.57 | 0.93 | (0.35) | — | (0.35) |
Year Ended 12/31/2018 | $10.36 | 0.33 | (0.29) | 0.04 | (0.25) | (0.07) | (0.32) |
Year Ended 12/31/2017 | $10.35 | 0.28 | 0.12 | 0.40 | (0.30) | (0.09) | (0.39) |
Year Ended 12/31/2016 | $10.07 | 0.30 | 0.17 | 0.47 | (0.18) | (0.01) | (0.19) |
Year Ended 12/31/2015 | $10.22 | 0.25 | (0.22) | 0.03 | (0.15) | (0.03) | (0.18) |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.04 | 0.33 | 0.57 | 0.90 | (0.32) | — | (0.32) |
Year Ended 12/31/2018 | $10.32 | 0.30 | (0.29) | 0.01 | (0.22) | (0.07) | (0.29) |
Year Ended 12/31/2017 | $10.31 | 0.25 | 0.12 | 0.37 | (0.27) | (0.09) | (0.36) |
Year Ended 12/31/2016 | $10.03 | 0.27 | 0.18 | 0.45 | (0.16) | (0.01) | (0.17) |
Year Ended 12/31/2015 | $10.19 | 0.22 | (0.23) | (0.01) | (0.12) | (0.03) | (0.15) |
Class 3 | |||||||
Year Ended 12/31/2019 | $10.09 | 0.35 | 0.56 | 0.91 | (0.33) | — | (0.33) |
Year Ended 12/31/2018 | $10.37 | 0.31 | (0.29) | 0.02 | (0.23) | (0.07) | (0.30) |
Year Ended 12/31/2017 | $10.36 | 0.27 | 0.11 | 0.38 | (0.28) | (0.09) | (0.37) |
Year Ended 12/31/2016 | $10.08 | 0.28 | 0.18 | 0.46 | (0.17) | (0.01) | (0.18) |
Year Ended 12/31/2015 | $10.23 | 0.24 | (0.22) | 0.02 | (0.14) | (0.03) | (0.17) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interest on collateral expense which is less than 0.01%. |
344 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.66 | 9.25% | 0.49% (c) | 0.49% (c) | 3.46% | 256% | $4,074,589 |
Year Ended 12/31/2018 | $10.08 | 0.40% | 0.49% (c) | 0.49% (c) | 3.21% | 222% | $3,919,654 |
Year Ended 12/31/2017 | $10.36 | 3.86% | 0.51% | 0.51% | 2.69% | 396% | $4,242,173 |
Year Ended 12/31/2016 | $10.35 | 4.68% | 0.54% | 0.54% | 2.86% | 400% | $4,384,210 |
Year Ended 12/31/2015 | $10.07 | 0.30% | 0.54% | 0.54% | 2.42% | 477% | $4,413,919 |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.62 | 9.03% | 0.74% (c) | 0.74% (c) | 3.19% | 256% | $53,012 |
Year Ended 12/31/2018 | $10.04 | 0.14% | 0.74% (c) | 0.74% (c) | 2.96% | 222% | $37,454 |
Year Ended 12/31/2017 | $10.32 | 3.61% | 0.76% | 0.76% | 2.44% | 396% | $37,866 |
Year Ended 12/31/2016 | $10.31 | 4.43% | 0.79% | 0.79% | 2.60% | 400% | $34,167 |
Year Ended 12/31/2015 | $10.03 | (0.05%) | 0.80% | 0.80% | 2.18% | 477% | $24,967 |
Class 3 | |||||||
Year Ended 12/31/2019 | $10.67 | 9.12% | 0.61% (c) | 0.61% (c) | 3.33% | 256% | $532,441 |
Year Ended 12/31/2018 | $10.09 | 0.27% | 0.61% (c) | 0.61% (c) | 3.07% | 222% | $518,931 |
Year Ended 12/31/2017 | $10.37 | 3.73% | 0.64% | 0.64% | 2.56% | 396% | $617,144 |
Year Ended 12/31/2016 | $10.36 | 4.54% | 0.66% | 0.66% | 2.74% | 400% | $688,625 |
Year Ended 12/31/2015 | $10.08 | 0.17% | 0.67% | 0.67% | 2.30% | 477% | $750,722 |
Prospectus 2020 | 345 |
Prospectus 2020 | 347 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $16.10 | 0.04 | 5.74 | 5.78 |
Year Ended 12/31/2018 | $16.76 | 0.03 | (0.69) | (0.66) |
Year Ended 12/31/2017 | $13.08 | 0.05 | 3.63 | 3.68 |
Year Ended 12/31/2016 | $12.92 | 0.09 | 0.07 | 0.16 |
Year Ended 12/31/2015 | $11.84 | 0.03 | 1.05 | 1.08 |
Class 2 | ||||
Year Ended 12/31/2019 | $15.76 | (0.01) | 5.61 | 5.60 |
Year Ended 12/31/2018 | $16.44 | (0.02) | (0.66) | (0.68) |
Year Ended 12/31/2017 | $12.86 | 0.02 | 3.56 | 3.58 |
Year Ended 12/31/2016 | $12.73 | 0.04 | 0.09 | 0.13 |
Year Ended 12/31/2015 | $11.70 | 0.00(c) | 1.03 | 1.03 |
Class 3 | ||||
Year Ended 12/31/2019 | $15.94 | 0.01 | 5.69 | 5.70 |
Year Ended 12/31/2018 | $16.62 | 0.01 | (0.69) | (0.68) |
Year Ended 12/31/2017 | $12.99 | 0.04 | 3.59 | 3.63 |
Year Ended 12/31/2016 | $12.84 | 0.07 | 0.08 | 0.15 |
Year Ended 12/31/2015 | $11.78 | 0.01 | 1.05 | 1.06 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
348 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $21.88 | 35.90% | 0.73% | 0.73% | 0.19% | 39% | $1,700,174 |
Year Ended 12/31/2018 | $16.10 | (3.94%) | 0.74% | 0.74% | 0.16% | 27% | $1,312,513 |
Year Ended 12/31/2017 | $16.76 | 28.14% | 0.77% | 0.76% | 0.36% | 35% | $1,408,054 |
Year Ended 12/31/2016 | $13.08 | 1.24% | 0.80% | 0.77% | 0.69% | 54% | $1,267,016 |
Year Ended 12/31/2015 | $12.92 | 9.12% | 0.80% | 0.79% | 0.23% | 56% | $1,198,464 |
Class 2 | |||||||
Year Ended 12/31/2019 | $21.36 | 35.53% | 0.98% | 0.98% | (0.06%) | 39% | $131,133 |
Year Ended 12/31/2018 | $15.76 | (4.14%) | 0.99% | 0.99% | (0.09%) | 27% | $108,782 |
Year Ended 12/31/2017 | $16.44 | 27.84% | 1.02% | 1.01% | 0.11% | 35% | $121,608 |
Year Ended 12/31/2016 | $12.86 | 1.02% | 1.05% | 1.01% | 0.35% | 54% | $108,824 |
Year Ended 12/31/2015 | $12.73 | 8.80% | 1.05% | 1.04% | (0.02%) | 56% | $32,835 |
Class 3 | |||||||
Year Ended 12/31/2019 | $21.64 | 35.76% | 0.86% | 0.86% | 0.06% | 39% | $230,850 |
Year Ended 12/31/2018 | $15.94 | (4.09%) | 0.86% | 0.86% | 0.04% | 27% | $196,874 |
Year Ended 12/31/2017 | $16.62 | 27.94% | 0.89% | 0.88% | 0.23% | 35% | $232,010 |
Year Ended 12/31/2016 | $12.99 | 1.17% | 0.92% | 0.89% | 0.55% | 54% | $207,757 |
Year Ended 12/31/2015 | $12.84 | 9.00% | 0.92% | 0.92% | 0.10% | 56% | $252,250 |
Prospectus 2020 | 349 |
Prospectus 2020 | 351 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $19.75 | 0.44 | 5.71 | 6.15 |
Year Ended 12/31/2018 | $20.72 | 0.42 | (1.39) | (0.97) |
Year Ended 12/31/2017 | $17.06 | 0.33 | 3.33 | 3.66 |
Year Ended 12/31/2016 | $15.29 | 0.34 | 1.43 | 1.77 |
Year Ended 12/31/2015 | $15.14 | 0.34(c) | (0.19) | 0.15 |
Class 2 | ||||
Year Ended 12/31/2019 | $19.39 | 0.37 | 5.60 | 5.97 |
Year Ended 12/31/2018 | $20.40 | 0.34 | (1.35) | (1.01) |
Year Ended 12/31/2017 | $16.83 | 0.28 | 3.29 | 3.57 |
Year Ended 12/31/2016 | $15.12 | 0.26 | 1.45 | 1.71 |
Year Ended 12/31/2015 | $15.01 | 0.29(d) | (0.18) | 0.11 |
Class 3 | ||||
Year Ended 12/31/2019 | $19.58 | 0.40 | 5.67 | 6.07 |
Year Ended 12/31/2018 | $20.57 | 0.37 | (1.36) | (0.99) |
Year Ended 12/31/2017 | $16.96 | 0.30 | 3.31 | 3.61 |
Year Ended 12/31/2016 | $15.21 | 0.28 | 1.47 | 1.75 |
Year Ended 12/31/2015 | $15.08 | 0.32(c) | (0.19) | 0.13 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.06 per share. |
(d) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.05 per share. |
352 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $25.90 | 31.14% | 0.26% | 0.26% | 1.91% | 2% | $599,584 |
Year Ended 12/31/2018 | $19.75 | (4.68%) | 0.28% | 0.28% | 1.94% | 3% | $332,816 |
Year Ended 12/31/2017 | $20.72 | 21.45% | 0.29% | 0.29% | 1.75% | 2% | $203,887 |
Year Ended 12/31/2016 | $17.06 | 11.58% | 0.32% | 0.31% | 2.14% | 5% | $31,465 |
Year Ended 12/31/2015 | $15.29 | 0.99% | 0.37% | 0.33% | 2.21% | 4% | $3 |
Class 2 | |||||||
Year Ended 12/31/2019 | $25.36 | 30.79% | 0.51% | 0.51% | 1.63% | 2% | $11,354 |
Year Ended 12/31/2018 | $19.39 | (4.95%) | 0.53% | 0.53% | 1.61% | 3% | $10,146 |
Year Ended 12/31/2017 | $20.40 | 21.21% | 0.55% | 0.55% | 1.50% | 2% | $11,777 |
Year Ended 12/31/2016 | $16.83 | 11.31% | 0.56% | 0.56% | 1.65% | 5% | $11,332 |
Year Ended 12/31/2015 | $15.12 | 0.73% | 0.58% | 0.58% | 1.94% | 4% | $11,794 |
Class 3 | |||||||
Year Ended 12/31/2019 | $25.65 | 31.00% | 0.39% | 0.39% | 1.76% | 2% | $599,751 |
Year Ended 12/31/2018 | $19.58 | (4.81%) | 0.40% | 0.40% | 1.75% | 3% | $442,813 |
Year Ended 12/31/2017 | $20.57 | 21.28% | 0.42% | 0.42% | 1.62% | 2% | $452,967 |
Year Ended 12/31/2016 | $16.96 | 11.51% | 0.43% | 0.43% | 1.78% | 5% | $347,922 |
Year Ended 12/31/2015 | $15.21 | 0.86% | 0.46% | 0.45% | 2.10% | 4% | $304,143 |
Prospectus 2020 | 353 |
Prospectus 2020 | 355 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $24.56 | 0.02 | 8.62 | 8.64 |
Year Ended 12/31/2018 | $25.79 | 0.03 | (1.26) | (1.23) |
Year Ended 12/31/2017 | $20.97 | 0.03 | 4.79 | 4.82 |
Year Ended 12/31/2016 | $20.50 | 0.03 | 0.44 | 0.47 |
Year Ended 12/31/2015 | $19.41 | 0.14(c) | 0.95 | 1.09 |
Class 2 | ||||
Year Ended 12/31/2019 | $24.06 | (0.06) | 8.44 | 8.38 |
Year Ended 12/31/2018 | $25.32 | (0.03) | (1.23) | (1.26) |
Year Ended 12/31/2017 | $20.64 | (0.03) | 4.71 | 4.68 |
Year Ended 12/31/2016 | $20.23 | 0.02 | 0.39 | 0.41 |
Year Ended 12/31/2015 | $19.20 | 0.23(d) | 0.80 | 1.03 |
Class 3 | ||||
Year Ended 12/31/2019 | $24.30 | (0.02) | 8.52 | 8.50 |
Year Ended 12/31/2018 | $25.54 | (0.00) (e) | (1.24) | (1.24) |
Year Ended 12/31/2017 | $20.80 | 0.00(e) | 4.74 | 4.74 |
Year Ended 12/31/2016 | $20.36 | 0.05 | 0.39 | 0.44 |
Year Ended 12/31/2015 | $19.30 | 0.25(f) | 0.81 | 1.06 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.14 per share. |
(d) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.27 per share. |
(e) | Rounds to zero. |
(f) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.28 per share. |
356 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $33.20 | 35.18% | 0.88% | 0.73% | 0.06% | 70% | $231,471 |
Year Ended 12/31/2018 | $24.56 | (4.77%) | 0.89% | 0.74% | 0.12% | 150% | $183,546 |
Year Ended 12/31/2017 | $25.79 | 22.98% | 0.91% | 0.74% | 0.14% | 115% | $198,617 |
Year Ended 12/31/2016 | $20.97 | 2.29% | 0.92% | 0.76% | 0.16% | 150% | $158,566 |
Year Ended 12/31/2015 | $20.50 | 5.62% | 0.94% | 0.84% | 0.67% | 109% | $18,161 |
Class 2 | |||||||
Year Ended 12/31/2019 | $32.44 | 34.83% | 1.13% | 0.98% | (0.19%) | 70% | $28,169 |
Year Ended 12/31/2018 | $24.06 | (4.98%) | 1.14% | 0.99% | (0.12%) | 150% | $19,966 |
Year Ended 12/31/2017 | $25.32 | 22.68% | 1.16% | 0.99% | (0.11%) | 115% | $18,148 |
Year Ended 12/31/2016 | $20.64 | 2.03% | 1.18% | 1.01% | 0.11% | 150% | $12,910 |
Year Ended 12/31/2015 | $20.23 | 5.36% | 1.20% | 1.05% | 1.11% | 109% | $13,920 |
Class 3 | |||||||
Year Ended 12/31/2019 | $32.80 | 34.98% | 1.01% | 0.85% | (0.07%) | 70% | $269,172 |
Year Ended 12/31/2018 | $24.30 | (4.86%) | 1.01% | 0.86% | (0.01%) | 150% | $227,630 |
Year Ended 12/31/2017 | $25.54 | 22.79% | 1.03% | 0.86% | 0.01% | 115% | $268,941 |
Year Ended 12/31/2016 | $20.80 | 2.16% | 1.05% | 0.88% | 0.24% | 150% | $247,151 |
Year Ended 12/31/2015 | $20.36 | 5.49% | 1.07% | 0.92% | 1.24% | 109% | $279,919 |
Prospectus 2020 | 357 |
Prospectus 2020 | 359 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $12.74 | 0.29 | 2.71 | 3.00 | (0.29) | (2.05) | (2.34) |
Year Ended 12/31/2018 | $15.71 | 0.29 | (2.84) | (2.55) | (0.42) | — | (0.42) |
Year Ended 12/31/2017 | $12.58 | 0.19 | 3.23 | 3.42 | (0.29) | — | (0.29) |
Year Ended 12/31/2016 | $13.60 | 0.22 | (1.04) | (0.82) | (0.20) | — | (0.20) |
Year Ended 12/31/2015 | $13.06 | 0.13 | 0.55 | 0.68 | (0.14) | — | (0.14) |
Class 2 | |||||||
Year Ended 12/31/2019 | $12.67 | 0.26 | 2.69 | 2.95 | (0.25) | (2.05) | (2.30) |
Year Ended 12/31/2018 | $15.62 | 0.26 | (2.83) | (2.57) | (0.38) | — | (0.38) |
Year Ended 12/31/2017 | $12.52 | 0.16 | 3.20 | 3.36 | (0.26) | — | (0.26) |
Year Ended 12/31/2016 | $13.55 | 0.22 | (1.07) | (0.85) | (0.18) | — | (0.18) |
Year Ended 12/31/2015 | $13.02 | 0.08 | 0.56 | 0.64 | (0.11) | — | (0.11) |
Class 3 | |||||||
Year Ended 12/31/2019 | $12.72 | 0.28 | 2.70 | 2.98 | (0.27) | (2.05) | (2.32) |
Year Ended 12/31/2018 | $15.68 | 0.28 | (2.84) | (2.56) | (0.40) | — | (0.40) |
Year Ended 12/31/2017 | $12.56 | 0.18 | 3.22 | 3.40 | (0.28) | — | (0.28) |
Year Ended 12/31/2016 | $13.58 | 0.21 | (1.04) | (0.83) | (0.19) | — | (0.19) |
Year Ended 12/31/2015 | $13.05 | 0.11 | 0.55 | 0.66 | (0.13) | — | (0.13) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interest on collateral expense which is less than 0.01%. |
(d) | Ratios include line of credit interest expense which is less than 0.01%. |
360 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $13.40 | 25.47% | 0.89% | 0.89% | 2.21% | 39% | $948,377 |
Year Ended 12/31/2018 | $12.74 | (16.63%) | 0.89% (c) | 0.89% (c) | 1.96% | 113% | $706,469 |
Year Ended 12/31/2017 | $15.71 | 27.52% | 0.91% | 0.90% | 1.38% | 41% | $792,289 |
Year Ended 12/31/2016 | $12.58 | (6.00%) | 0.93% (d) | 0.89% (d) | 1.76% | 57% | $604,967 |
Year Ended 12/31/2015 | $13.60 | 5.20% | 1.01% | 0.93% | 0.91% | 57% | $11,981 |
Class 2 | |||||||
Year Ended 12/31/2019 | $13.32 | 25.15% | 1.14% | 1.14% | 1.95% | 39% | $59,746 |
Year Ended 12/31/2018 | $12.67 | (16.81%) | 1.14% (c) | 1.14% (c) | 1.75% | 113% | $51,287 |
Year Ended 12/31/2017 | $15.62 | 27.18% | 1.16% | 1.15% | 1.13% | 41% | $67,097 |
Year Ended 12/31/2016 | $12.52 | (6.27%) | 1.17% (d) | 1.14% (d) | 1.77% | 57% | $57,342 |
Year Ended 12/31/2015 | $13.55 | 4.94% | 1.28% | 1.18% | 0.61% | 57% | $16,240 |
Class 3 | |||||||
Year Ended 12/31/2019 | $13.38 | 25.32% | 1.01% | 1.01% | 2.09% | 39% | $250,480 |
Year Ended 12/31/2018 | $12.72 | (16.70%) | 1.02% (c) | 1.02% (c) | 1.88% | 113% | $228,786 |
Year Ended 12/31/2017 | $15.68 | 27.37% | 1.04% | 1.03% | 1.26% | 41% | $312,588 |
Year Ended 12/31/2016 | $12.56 | (6.10%) | 1.07% (d) | 1.03% (d) | 1.66% | 57% | $280,282 |
Year Ended 12/31/2015 | $13.58 | 5.03% | 1.14% | 1.05% | 0.79% | 57% | $314,648 |
Prospectus 2020 | 361 |
Prospectus 2020 | 363 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $21.83 | 0.43 | 5.41 | 5.84 |
Year Ended 12/31/2018 | $24.87 | 0.40 | (3.44) | (3.04) |
Year Ended 12/31/2017 | $20.56 | 0.30 | 4.01 | 4.31 |
Year Ended 12/31/2016 | $17.14 | 0.26 | 3.16 | 3.42 |
Year Ended 12/31/2015 | $18.02 | 0.27 | (1.15) | (0.88) |
Class 2 | ||||
Year Ended 12/31/2019 | $21.38 | 0.36 | 5.29 | 5.65 |
Year Ended 12/31/2018 | $24.42 | 0.33 | (3.37) | (3.04) |
Year Ended 12/31/2017 | $20.23 | 0.24 | 3.95 | 4.19 |
Year Ended 12/31/2016 | $16.91 | 0.22 | 3.10 | 3.32 |
Year Ended 12/31/2015 | $17.83 | 0.23 | (1.15) | (0.92) |
Class 3 | ||||
Year Ended 12/31/2019 | $21.59 | 0.39 | 5.34 | 5.73 |
Year Ended 12/31/2018 | $24.62 | 0.36 | (3.39) | (3.03) |
Year Ended 12/31/2017 | $20.38 | 0.27 | 3.97 | 4.24 |
Year Ended 12/31/2016 | $17.01 | 0.24 | 3.13 | 3.37 |
Year Ended 12/31/2015 | $17.91 | 0.25 | (1.15) | (0.90) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interfund lending expense which is less than 0.01%. |
364 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $27.67 | 26.75% | 0.73% (c) | 0.73% (c) | 1.73% | 11% | $1,241,829 |
Year Ended 12/31/2018 | $21.83 | (12.22%) | 0.73% | 0.73% | 1.60% | 16% | $1,102,434 |
Year Ended 12/31/2017 | $24.87 | 20.96% | 0.76% | 0.75% | 1.35% | 8% | $1,322,918 |
Year Ended 12/31/2016 | $20.56 | 19.95% | 0.82% | 0.77% | 1.49% | 26% | $1,046,757 |
Year Ended 12/31/2015 | $17.14 | (4.88%) | 0.81% | 0.76% | 1.54% | 13% | $779,920 |
Class 2 | |||||||
Year Ended 12/31/2019 | $27.03 | 26.43% | 0.98% (c) | 0.98% (c) | 1.48% | 11% | $32,815 |
Year Ended 12/31/2018 | $21.38 | (12.45%) | 0.98% | 0.98% | 1.36% | 16% | $24,610 |
Year Ended 12/31/2017 | $24.42 | 20.71% | 1.01% | 1.00% | 1.10% | 8% | $22,501 |
Year Ended 12/31/2016 | $20.23 | 19.63% | 1.07% | 1.02% | 1.25% | 26% | $15,026 |
Year Ended 12/31/2015 | $16.91 | (5.16%) | 1.06% | 1.02% | 1.32% | 13% | $11,918 |
Class 3 | |||||||
Year Ended 12/31/2019 | $27.32 | 26.54% | 0.86% (c) | 0.86% (c) | 1.61% | 11% | $56,957 |
Year Ended 12/31/2018 | $21.59 | (12.31%) | 0.85% | 0.85% | 1.48% | 16% | $48,804 |
Year Ended 12/31/2017 | $24.62 | 20.81% | 0.89% | 0.88% | 1.22% | 8% | $56,053 |
Year Ended 12/31/2016 | $20.38 | 19.81% | 0.95% | 0.89% | 1.39% | 26% | $45,889 |
Year Ended 12/31/2015 | $17.01 | (5.02%) | 0.94% | 0.89% | 1.42% | 13% | $47,307 |
Prospectus 2020 | 365 |
Prospectus 2020 | 367 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $19.70 | 0.29 | 5.94 | 6.23 |
Year Ended 12/31/2018 | $22.72 | 0.20 | (3.22) | (3.02) |
Year Ended 12/31/2017 | $20.01 | 0.25 | 2.46 | 2.71 |
Year Ended 12/31/2016 | $17.53 | 0.23 | 2.25 | 2.48 |
Year Ended 12/31/2015 | $18.45 | 0.07 | (0.99) | (0.92) |
Class 2 | ||||
Year Ended 12/31/2019 | $19.33 | 0.22 | 5.82 | 6.04 |
Year Ended 12/31/2018 | $22.35 | 0.14 | (3.16) | (3.02) |
Year Ended 12/31/2017 | $19.73 | 0.20 | 2.42 | 2.62 |
Year Ended 12/31/2016 | $17.33 | 0.14 | 2.26 | 2.40 |
Year Ended 12/31/2015 | $18.26 | 0.07 | (1.00) | (0.93) |
Class 3 | ||||
Year Ended 12/31/2019 | $19.51 | 0.25 | 5.88 | 6.13 |
Year Ended 12/31/2018 | $22.53 | 0.16 | (3.18) | (3.02) |
Year Ended 12/31/2017 | $19.87 | 0.22 | 2.44 | 2.66 |
Year Ended 12/31/2016 | $17.43 | 0.16 | 2.28 | 2.44 |
Year Ended 12/31/2015 | $18.34 | 0.09 | (1.00) | (0.91) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include line of credit interest expense which is less than 0.01%. |
368 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $25.93 | 31.62% | 0.88% | 0.82% | 1.22% | 31% | $220,919 |
Year Ended 12/31/2018 | $19.70 | (13.29%) | 0.89% | 0.85% | 0.87% | 98% | $170,998 |
Year Ended 12/31/2017 | $22.72 | 13.54% | 0.91% | 0.87% | 1.20% | 72% | $191,281 |
Year Ended 12/31/2016 | $20.01 | 14.15% | 0.93% | 0.90% | 1.25% | 57% | $162,796 |
Year Ended 12/31/2015 | $17.53 | (4.99%) | 0.91% (c) | 0.90% (c) | 0.38% | 43% | $12,613 |
Class 2 | |||||||
Year Ended 12/31/2019 | $25.37 | 31.25% | 1.13% | 1.07% | 0.97% | 31% | $34,239 |
Year Ended 12/31/2018 | $19.33 | (13.51%) | 1.14% | 1.10% | 0.62% | 98% | $25,687 |
Year Ended 12/31/2017 | $22.35 | 13.28% | 1.16% | 1.12% | 0.97% | 72% | $28,989 |
Year Ended 12/31/2016 | $19.73 | 13.85% | 1.19% | 1.16% | 0.79% | 57% | $22,379 |
Year Ended 12/31/2015 | $17.33 | (5.09%) | 1.22% (c) | 1.17% (c) | 0.40% | 43% | $17,179 |
Class 3 | |||||||
Year Ended 12/31/2019 | $25.64 | 31.42% | 1.01% | 0.95% | 1.08% | 31% | $68,354 |
Year Ended 12/31/2018 | $19.51 | (13.40%) | 1.01% | 0.97% | 0.73% | 98% | $61,387 |
Year Ended 12/31/2017 | $22.53 | 13.39% | 1.04% | 0.99% | 1.05% | 72% | $85,853 |
Year Ended 12/31/2016 | $19.87 | 14.00% | 1.07% | 1.03% | 0.88% | 57% | $92,137 |
Year Ended 12/31/2015 | $17.43 | (4.96%) | 1.09% (c) | 1.04% (c) | 0.50% | 43% | $97,276 |
Prospectus 2020 | 369 |
Prospectus 2020 | 371 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $21.25 | 0.16 | 3.61 | 3.77 |
Year Ended 12/31/2018 | $24.31 | 0.11 | (3.17) | (3.06) |
Year Ended 12/31/2017 | $21.65 | (0.02) | 2.68 | 2.66 |
Year Ended 12/31/2016 | $19.00 | 0.00(c) | 2.65 | 2.65 |
Year Ended 12/31/2015 | $19.60 | 0.00(c) | (0.60) | (0.60) |
Class 2 | ||||
Year Ended 12/31/2019 | $20.81 | 0.10 | 3.53 | 3.63 |
Year Ended 12/31/2018 | $23.87 | 0.05 | (3.11) | (3.06) |
Year Ended 12/31/2017 | $21.30 | 0.04 | 2.53 | 2.57 |
Year Ended 12/31/2016 | $18.74 | (0.04) | 2.60 | 2.56 |
Year Ended 12/31/2015 | $19.38 | (0.04) | (0.60) | (0.64) |
Class 3 | ||||
Year Ended 12/31/2019 | $21.04 | 0.14 | 3.56 | 3.70 |
Year Ended 12/31/2018 | $24.10 | 0.08 | (3.14) | (3.06) |
Year Ended 12/31/2017 | $21.48 | 0.06 | 2.56 | 2.62 |
Year Ended 12/31/2016 | $18.87 | (0.02) | 2.63 | 2.61 |
Year Ended 12/31/2015 | $19.50 | (0.02) | (0.61) | (0.63) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
(d) | Ratios include line of credit interest expense which is less than 0.01%. |
372 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $25.02 | 17.74% | 1.05% | 0.88% | 0.68% | 21% | $4,280 |
Year Ended 12/31/2018 | $21.25 | (12.59%) | 1.04% | 0.88% | 0.43% | 13% | $3,163 |
Year Ended 12/31/2017 | $24.31 | 12.29% | 1.02% | 0.89% | (0.09%) | 23% | $4,111 |
Year Ended 12/31/2016 | $21.65 | 13.95% | 1.00% (d) | 0.91% (d) | 0.02% | 32% | $16,013 |
Year Ended 12/31/2015 | $19.00 | (3.06%) | 0.99% | 0.91% | 0.01% | 27% | $60,663 |
Class 2 | |||||||
Year Ended 12/31/2019 | $24.44 | 17.44% | 1.30% | 1.13% | 0.44% | 21% | $26,851 |
Year Ended 12/31/2018 | $20.81 | (12.82%) | 1.29% | 1.13% | 0.20% | 13% | $24,086 |
Year Ended 12/31/2017 | $23.87 | 12.06% | 1.29% | 1.14% | 0.19% | 23% | $28,050 |
Year Ended 12/31/2016 | $21.30 | 13.66% | 1.27% (d) | 1.16% (d) | (0.22%) | 32% | $25,233 |
Year Ended 12/31/2015 | $18.74 | (3.30%) | 1.24% | 1.16% | (0.22%) | 27% | $22,315 |
Class 3 | |||||||
Year Ended 12/31/2019 | $24.74 | 17.59% | 1.18% | 1.00% | 0.57% | 21% | $52,643 |
Year Ended 12/31/2018 | $21.04 | (12.70%) | 1.17% | 1.01% | 0.33% | 13% | $51,927 |
Year Ended 12/31/2017 | $24.10 | 12.20% | 1.16% | 1.02% | 0.25% | 23% | $67,684 |
Year Ended 12/31/2016 | $21.48 | 13.83% | 1.14% (d) | 1.03% (d) | (0.10%) | 32% | $71,355 |
Year Ended 12/31/2015 | $18.87 | (3.23%) | 1.11% | 1.04% | (0.11%) | 27% | $73,318 |
Prospectus 2020 | 373 |
Prospectus 2020 | 375 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.23 | 0.30 | 0.38 | 0.68 | (0.29) | — | (0.29) |
Year Ended 12/31/2018 | $10.35 | 0.30 | (0.11) | 0.19 | (0.30) | (0.01) | (0.31) |
Year Ended 12/31/2017 | $10.32 | 0.29 | 0.05 | 0.34 | (0.30) | (0.01) | (0.31) |
Year Ended 12/31/2016 | $10.42 | 0.25 | 0.03 | 0.28 | (0.30) | (0.08) | (0.38) |
Year Ended 12/31/2015 | $10.62 | 0.26 | (0.12) | 0.14 | (0.32) | (0.02) | (0.34) |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.20 | 0.27 | 0.39 | 0.66 | (0.27) | — | (0.27) |
Year Ended 12/31/2018 | $10.32 | 0.27 | (0.11) | 0.16 | (0.27) | (0.01) | (0.28) |
Year Ended 12/31/2017 | $10.30 | 0.26 | 0.05 | 0.31 | (0.28) | (0.01) | (0.29) |
Year Ended 12/31/2016 | $10.40 | 0.22 | 0.04 | 0.26 | (0.28) | (0.08) | (0.36) |
Year Ended 12/31/2015 | $10.59 | 0.23 | (0.10) | 0.13 | (0.30) | (0.02) | (0.32) |
Class 3 | |||||||
Year Ended 12/31/2019 | $10.23 | 0.28 | 0.39 | 0.67 | (0.28) | — | (0.28) |
Year Ended 12/31/2018 | $10.35 | 0.28 | (0.11) | 0.17 | (0.28) | (0.01) | (0.29) |
Year Ended 12/31/2017 | $10.32 | 0.27 | 0.06 | 0.33 | (0.29) | (0.01) | (0.30) |
Year Ended 12/31/2016 | $10.42 | 0.24 | 0.03 | 0.27 | (0.29) | (0.08) | (0.37) |
Year Ended 12/31/2015 | $10.62 | 0.25 | (0.12) | 0.13 | (0.31) | (0.02) | (0.33) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interest on collateral expense which is less than 0.01%. |
376 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.62 | 6.73% | 0.46% (c) | 0.46% (c) | 2.83% | 335% | $888,047 |
Year Ended 12/31/2018 | $10.23 | 1.85% | 0.46% (c) | 0.46% (c) | 2.91% | 286% | $847,752 |
Year Ended 12/31/2017 | $10.35 | 3.34% | 0.48% | 0.48% | 2.77% | 320% | $898,922 |
Year Ended 12/31/2016 | $10.32 | 2.71% | 0.50% | 0.50% | 2.38% | 333% | $1,031,382 |
Year Ended 12/31/2015 | $10.42 | 1.34% | 0.50% | 0.50% | 2.45% | 356% | $1,247,913 |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.59 | 6.50% | 0.71% (c) | 0.71% (c) | 2.57% | 335% | $25,616 |
Year Ended 12/31/2018 | $10.20 | 1.60% | 0.71% (c) | 0.71% (c) | 2.66% | 286% | $22,932 |
Year Ended 12/31/2017 | $10.32 | 2.99% | 0.73% | 0.73% | 2.52% | 320% | $24,782 |
Year Ended 12/31/2016 | $10.30 | 2.45% | 0.75% | 0.75% | 2.13% | 333% | $25,112 |
Year Ended 12/31/2015 | $10.40 | 1.19% | 0.75% | 0.75% | 2.20% | 356% | $24,470 |
Class 3 | |||||||
Year Ended 12/31/2019 | $10.62 | 6.61% | 0.59% (c) | 0.59% (c) | 2.71% | 335% | $94,876 |
Year Ended 12/31/2018 | $10.23 | 1.72% | 0.58% (c) | 0.58% (c) | 2.78% | 286% | $99,204 |
Year Ended 12/31/2017 | $10.35 | 3.22% | 0.61% | 0.61% | 2.65% | 320% | $120,079 |
Year Ended 12/31/2016 | $10.32 | 2.58% | 0.62% | 0.62% | 2.25% | 333% | $139,813 |
Year Ended 12/31/2015 | $10.42 | 1.21% | 0.62% | 0.62% | 2.33% | 356% | $151,492 |
Prospectus 2020 | 377 |
Prospectus 2020 | 379 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $5.42 | 0.03 | 0.40 | 0.43 | (0.19) | — | (0.19) |
Year Ended 12/31/2018 | $5.47 | 0.08 | (0.10) | (0.02) | — | (0.03) | (0.03) |
Year Ended 12/31/2017 | $5.51 | 0.06 | 0.08 | 0.14 | (0.13) | (0.05) | (0.18) |
Year Ended 12/31/2016 | $5.07 | 0.01 | 0.43 | 0.44 | — | — | — |
Year Ended 12/31/2015 | $9.49 | (0.07) | (0.01) (d) | (0.08) | (3.51) | (0.83) | (4.34) |
Class 2 | |||||||
Year Ended 12/31/2019 | $5.30 | 0.02 | 0.38 | 0.40 | (0.17) | — | (0.17) |
Year Ended 12/31/2018 | $5.37 | 0.06 | (0.10) | (0.04) | — | (0.03) | (0.03) |
Year Ended 12/31/2017 | $5.41 | 0.05 | 0.08 | 0.13 | (0.12) | (0.05) | (0.17) |
Year Ended 12/31/2016 | $4.99 | 0.00(e) | 0.42 | 0.42 | — | — | — |
Year Ended 12/31/2015 | $9.41 | (0.02) | (0.08) (d) | (0.10) | (3.49) | (0.83) | (4.32) |
Class 3 | |||||||
Year Ended 12/31/2019 | $5.39 | 0.03 | 0.39 | 0.42 | (0.18) | — | (0.18) |
Year Ended 12/31/2018 | $5.45 | 0.07 | (0.10) | (0.03) | — | (0.03) | (0.03) |
Year Ended 12/31/2017 | $5.49 | 0.05 | 0.08 | 0.13 | (0.12) | (0.05) | (0.17) |
Year Ended 12/31/2016 | $5.06 | 0.00(e) | 0.43 | 0.43 | — | — | — |
Year Ended 12/31/2015 | $9.48 | (0.02) | (0.07) (d) | (0.09) | (3.50) | (0.83) | (4.33) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interest on collateral expense which is less than 0.01%. |
(d) | Calculation of the net gain (loss) per share (both realized and unrealized) does not correlate to the aggregate realized and unrealized gain (loss) presented in the Statement of Operations due to the timing of subscriptions and redemptions of Fund shares in relation to fluctuations in the market value of the portfolio. |
(e) | Rounds to zero. |
380 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $5.66 | 7.90% | 0.71% (c) | 0.61% (c) | 0.57% | 62% | $28 |
Year Ended 12/31/2018 | $5.42 | (0.33%) | 0.71% (c) | 0.61% (c) | 1.41% | 118% | $11 |
Year Ended 12/31/2017 | $5.47 | 2.66% | 0.71% | 0.62% | 1.09% | 99% | $11 |
Year Ended 12/31/2016 | $5.51 | 8.68% | 0.68% | 0.64% | 0.18% | 72% | $11 |
Year Ended 12/31/2015 | $5.07 | (1.38%) | 0.58% | 0.58% | (0.77%) | 89% | $11 |
Class 2 | |||||||
Year Ended 12/31/2019 | $5.53 | 7.63% | 0.96% (c) | 0.86% (c) | 0.38% | 62% | $19,663 |
Year Ended 12/31/2018 | $5.30 | (0.71%) | 0.95% (c) | 0.86% (c) | 1.14% | 118% | $17,272 |
Year Ended 12/31/2017 | $5.37 | 2.46% | 0.97% | 0.87% | 0.86% | 99% | $13,986 |
Year Ended 12/31/2016 | $5.41 | 8.42% | 0.93% | 0.89% | (0.07%) | 72% | $10,801 |
Year Ended 12/31/2015 | $4.99 | (1.64%) | 0.89% | 0.86% | (0.28%) | 89% | $7,898 |
Class 3 | |||||||
Year Ended 12/31/2019 | $5.63 | 7.81% | 0.83% (c) | 0.73% (c) | 0.49% | 62% | $89,128 |
Year Ended 12/31/2018 | $5.39 | (0.51%) | 0.82% (c) | 0.74% (c) | 1.28% | 118% | $96,659 |
Year Ended 12/31/2017 | $5.45 | 2.54% | 0.84% | 0.75% | 0.97% | 99% | $111,829 |
Year Ended 12/31/2016 | $5.49 | 8.50% | 0.80% | 0.77% | 0.05% | 72% | $123,299 |
Year Ended 12/31/2015 | $5.06 | (1.49%) | 0.76% | 0.74% | (0.23%) | 89% | $135,276 |
Prospectus 2020 | 381 |
Prospectus 2020 | 383 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Calculation of the net gain (loss) per share (both realized and unrealized) does not correlate to the aggregate realized and unrealized gain (loss) presented in the Statement of Operations due to the timing of subscriptions and redemptions of Fund shares in relation to fluctuations in the market value of the portfolio. |
(d) | Rounds to zero. |
384 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $30.32 | 28.20% | 0.79% | 0.79% | 1.25% | 39% | $534,959 |
Year Ended 12/31/2018 | $23.65 | (9.97%) | 0.79% | 0.79% | 1.00% | 36% | $442,931 |
Year Ended 12/31/2017 | $26.27 | 15.83% | 0.82% | 0.82% | 0.69% | 41% | $487,245 |
Year Ended 12/31/2016 | $22.68 | 20.77% | 0.88% | 0.86% | 0.71% | 46% | $409,756 |
Year Ended 12/31/2015 | $18.78 | 0.27% | 0.91% | 0.89% | 0.71% | 53% | $176,428 |
Class 2 | |||||||
Year Ended 12/31/2019 | $29.61 | 27.85% | 1.04% | 1.04% | 1.00% | 39% | $54,158 |
Year Ended 12/31/2018 | $23.16 | (10.20%) | 1.04% | 1.04% | 0.76% | 36% | $40,488 |
Year Ended 12/31/2017 | $25.79 | 15.55% | 1.07% | 1.07% | 0.46% | 41% | $40,477 |
Year Ended 12/31/2016 | $22.32 | 20.52% | 1.14% | 1.11% | 0.49% | 46% | $26,182 |
Year Ended 12/31/2015 | $18.52 | 0.00% (d) | 1.18% | 1.14% | 0.63% | 53% | $14,431 |
Class 3 | |||||||
Year Ended 12/31/2019 | $29.98 | 28.01% | 0.91% | 0.91% | 1.12% | 39% | $67,484 |
Year Ended 12/31/2018 | $23.42 | (10.10%) | 0.92% | 0.92% | 0.88% | 36% | $53,581 |
Year Ended 12/31/2017 | $26.05 | 15.73% | 0.95% | 0.95% | 0.57% | 41% | $57,946 |
Year Ended 12/31/2016 | $22.51 | 20.63% | 1.01% | 0.99% | 0.61% | 46% | $44,076 |
Year Ended 12/31/2015 | $18.66 | 0.16% | 1.05% | 1.02% | 0.73% | 53% | $27,637 |
Prospectus 2020 | 385 |
Prospectus 2020 | 387 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $18.84 | 0.27 | 4.74 | 5.01 |
Year Ended 12/31/2018 | $20.48 | 0.24 | (1.88) | (1.64) |
Year Ended 12/31/2017 | $17.00 | 0.20 | 3.28 | 3.48 |
Year Ended 12/31/2016 | $15.49 | 0.22 | 1.29 | 1.51 |
Year Ended 12/31/2015 | $15.40 | 0.64(c) | (0.55) | 0.09 |
Class 2 | ||||
Year Ended 12/31/2019 | $18.47 | 0.21 | 4.63 | 4.84 |
Year Ended 12/31/2018 | $20.12 | 0.18 | (1.83) | (1.65) |
Year Ended 12/31/2017 | $16.75 | 0.15 | 3.22 | 3.37 |
Year Ended 12/31/2016 | $15.29 | 0.18 | 1.28 | 1.46 |
Year Ended 12/31/2015 | $15.24 | 0.65(d) | (0.60) | 0.05 |
Class 3 | ||||
Year Ended 12/31/2019 | $18.65 | 0.24 | 4.68 | 4.92 |
Year Ended 12/31/2018 | $20.29 | 0.21 | (1.85) | (1.64) |
Year Ended 12/31/2017 | $16.87 | 0.18 | 3.24 | 3.42 |
Year Ended 12/31/2016 | $15.38 | 0.20 | 1.29 | 1.49 |
Year Ended 12/31/2015 | $15.31 | 0.62(c) | (0.55) | 0.07 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.39 per share. |
(d) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.43 per share. |
388 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $23.85 | 26.59% | 0.70% | 0.69% | 1.25% | 129% | $2,237,714 |
Year Ended 12/31/2018 | $18.84 | (8.01%) | 0.70% | 0.69% | 1.13% | 55% | $1,775,821 |
Year Ended 12/31/2017 | $20.48 | 20.47% | 0.74% | 0.74% | 1.08% | 51% | $1,934,400 |
Year Ended 12/31/2016 | $17.00 | 9.75% | 0.79% | 0.77% | 1.39% | 115% | $1,670,305 |
Year Ended 12/31/2015 | $15.49 | 0.58% | 0.82% | 0.77% | 4.14% | 67% | $1,691,555 |
Class 2 | |||||||
Year Ended 12/31/2019 | $23.31 | 26.21% | 0.95% | 0.94% | 1.00% | 129% | $10,760 |
Year Ended 12/31/2018 | $18.47 | (8.20%) | 0.95% | 0.94% | 0.88% | 55% | $9,255 |
Year Ended 12/31/2017 | $20.12 | 20.12% | 0.99% | 0.99% | 0.83% | 51% | $10,507 |
Year Ended 12/31/2016 | $16.75 | 9.55% | 1.04% | 1.02% | 1.13% | 115% | $8,549 |
Year Ended 12/31/2015 | $15.29 | 0.33% | 1.07% | 1.02% | 4.22% | 67% | $8,239 |
Class 3 | |||||||
Year Ended 12/31/2019 | $23.57 | 26.38% | 0.83% | 0.81% | 1.13% | 129% | $32,859 |
Year Ended 12/31/2018 | $18.65 | (8.08%) | 0.83% | 0.82% | 1.00% | 55% | $31,196 |
Year Ended 12/31/2017 | $20.29 | 20.27% | 0.87% | 0.87% | 0.96% | 51% | $42,254 |
Year Ended 12/31/2016 | $16.87 | 9.69% | 0.92% | 0.90% | 1.27% | 115% | $42,830 |
Year Ended 12/31/2015 | $15.38 | 0.46% | 0.95% | 0.89% | 4.04% | 67% | $46,975 |
Prospectus 2020 | 389 |
Prospectus 2020 | 391 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Increase
from payment by affiliate |
Total from
investment operations |
|
Class 1 | |||||
Year Ended 12/31/2019 | $24.24 | 0.28 | 4.52 | — | 4.80 |
Year Ended 12/31/2018 | $28.01 | 0.25 | (4.02) | — | (3.77) |
Year Ended 12/31/2017 | $26.14 | 0.19 | 1.68 | — | 1.87 |
Year Ended 12/31/2016 | $20.81 | 0.09 | 5.24 | 0.00(c) | 5.33 |
Year Ended 12/31/2015 | $22.92 | 0.19 | (2.30) | — | (2.11) |
Class 2 | |||||
Year Ended 12/31/2019 | $23.71 | 0.22 | 4.41 | — | 4.63 |
Year Ended 12/31/2018 | $27.48 | 0.18 | (3.95) | — | (3.77) |
Year Ended 12/31/2017 | $25.71 | 0.13 | 1.64 | — | 1.77 |
Year Ended 12/31/2016 | $20.51 | 0.04 | 5.16 | 0.00(c) | 5.20 |
Year Ended 12/31/2015 | $22.65 | 0.14 | (2.28) | — | (2.14) |
Class 3 | |||||
Year Ended 12/31/2019 | $23.96 | 0.25 | 4.46 | — | 4.71 |
Year Ended 12/31/2018 | $27.73 | 0.21 | (3.98) | — | (3.77) |
Year Ended 12/31/2017 | $25.91 | 0.15 | 1.67 | — | 1.82 |
Year Ended 12/31/2016 | $20.64 | 0.06 | 5.21 | 0.00(c) | 5.27 |
Year Ended 12/31/2015 | $22.77 | 0.17 | (2.30) | — | (2.13) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
(d) | The Fund received a payment from an affiliate. Had the Fund not received this payment, the total return would have been lower by 0.01%. |
392 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $29.04 | 19.80% | 0.89% | 0.88% | 1.02% | 75% | $566,653 |
Year Ended 12/31/2018 | $24.24 | (13.46%) | 0.88% | 0.88% | 0.88% | 60% | $574,250 |
Year Ended 12/31/2017 | $28.01 | 7.16% | 0.91% | 0.91% | 0.72% | 115% | $686,191 |
Year Ended 12/31/2016 | $26.14 | 25.61% (d) | 1.02% | 0.93% | 0.40% | 60% | $712,682 |
Year Ended 12/31/2015 | $20.81 | (9.21%) | 1.07% | 0.93% | 0.84% | 48% | $985,530 |
Class 2 | |||||||
Year Ended 12/31/2019 | $28.34 | 19.53% | 1.14% | 1.13% | 0.81% | 75% | $8,276 |
Year Ended 12/31/2018 | $23.71 | (13.72%) | 1.13% | 1.13% | 0.65% | 60% | $6,673 |
Year Ended 12/31/2017 | $27.48 | 6.88% | 1.16% | 1.16% | 0.49% | 115% | $6,814 |
Year Ended 12/31/2016 | $25.71 | 25.35% (d) | 1.25% | 1.18% | 0.17% | 60% | $5,749 |
Year Ended 12/31/2015 | $20.51 | (9.45%) | 1.32% | 1.18% | 0.65% | 48% | $4,017 |
Class 3 | |||||||
Year Ended 12/31/2019 | $28.67 | 19.66% | 1.01% | 1.00% | 0.92% | 75% | $94,282 |
Year Ended 12/31/2018 | $23.96 | (13.60%) | 1.01% | 1.00% | 0.74% | 60% | $89,379 |
Year Ended 12/31/2017 | $27.73 | 7.02% | 1.04% | 1.04% | 0.59% | 115% | $120,392 |
Year Ended 12/31/2016 | $25.91 | 25.53% (d) | 1.13% | 1.05% | 0.29% | 60% | $134,434 |
Year Ended 12/31/2015 | $20.64 | (9.36%) | 1.19% | 1.05% | 0.77% | 48% | $129,360 |
Prospectus 2020 | 393 |
Fund | Prospectus Dated |
Columbia Funds Variable Series Trust II | |
Variable Portfolio - Partners International Core Equity Fund (the Fund) | 5/1/2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
James Gautrey, CFA | Portfolio Manager of Schroders | Co-Portfolio Manager | the Effective Date | |||
Simon Webber, CFA | Portfolio Manager of Schroders | Co-Portfolio Manager | the Effective Date |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
James Gautrey, CFA | Portfolio Manager of Schroders | Co-Portfolio Manager | the Effective Date | |||
Simon Webber, CFA | Portfolio Manager of Schroders | Co-Portfolio Manager | the Effective Date |
Fund | Prospectus Dated |
Columbia Funds Variable Series Trust II | |
Variable Portfolio - Partners International Growth Fund (the Fund) | 5/1/2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Roy Leckie | Executive Director of Walter Scott and Co-Chair of Walter Scott’s IMC | IE Member (portfolio management) | the Effective Date | |||
Charlie Macquaker | Executive Director of Walter Scott and Co-Chair of Walter Scott’s IMC | IE Member (portfolio management) | the Effective Date | |||
Jane Henderson | Managing Director of Walter Scott | IE Member (portfolio management) | the Effective Date |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Roy Leckie | Executive Director of Walter Scott and Co-Chair of Walter Scott’s IMC | IE Member (portfolio management) | the Effective Date | |||
Charlie Macquaker | Executive Director of Walter Scott and Co-Chair of Walter Scott’s IMC | IE Member (portfolio management) | the Effective Date | |||
Jane Henderson | Managing Director of Walter Scott | IE Member (portfolio management) | the Effective Date |
Fund | Prospectus Dated |
Columbia Funds Variable Series Trust II | |
Variable Portfolio - Partners International Value Fund (the Fund) | 5/1/2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brandon Harrell, CFA | Portfolio Manager of TSW | Co-Portfolio Manager | the Effective Date |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brandon Harrell, CFA | Portfolio Manager of TSW | Co-Portfolio Manager | the Effective Date |
SUMMARIES OF THE FUNDS
Investment Objective(s), Fees and Expenses of the Fund, Principal Investment Strategies, Principal Risks, Performance Information, Fund Management, Purchase and Sale of Fund Shares, Tax Information, Payments to Broker-Dealers and Other Financial Intermediaries |
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MORE INFORMATION ABOUT THE FUNDS
Investment Objective(s), Principal Investment Strategies, Principal Risks, Portfolio Management |
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Prospectus 2020 | 1 |
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2 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.49% for Class 1 and 0.74% for Class 2. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $50 | $159 | $279 | $627 |
Class 2 (whether or not shares are redeemed) | $76 | $239 | $416 | $929 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
8 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 2.81% |
Worst
|
3rd Quarter 2015 | -1.77% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 7.69% | 2.58% | 2.72% |
Class 2 | 05/07/2010 | 7.47% | 2.35% | 2.46% |
Bloomberg Barclays U.S. 1-5 Year Corporate Index (reflects no deductions for fees, expenses or taxes) | 6.99% | 2.90% | 3.15% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Tom Murphy, CFA | Vice President, Senior Portfolio Manager and Head of Investment Grade Credit | Lead Portfolio Manager | 2010 | |||
Royce D. Wilson, CFA | Senior Portfolio Manager | Portfolio Manager | 2012 | |||
John Dawson, CFA | Portfolio Manager | Portfolio Manager | February 2020 |
Prospectus 2020 | 9 |
10 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $51 | $160 | $280 | $628 |
Class 2 (whether or not shares are redeemed) | $77 | $240 | $417 | $930 |
Prospectus 2020 | 11 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
16 | Prospectus 2020 |
Prospectus 2020 | 17 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 3.96% |
Worst
|
2nd Quarter 2013 | -2.72% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 9.73% | 3.39% | 3.72% |
Class 2 | 05/07/2010 | 9.40% | 3.12% | 3.46% |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Robert Gahagan | Senior Vice President and Senior Portfolio Manager of American Century (Global Macro Strategy Team Representative) | Co-Portfolio Manager | 2010 | |||
Alejandro Aguilar, CFA | Vice President and Senior Portfolio Manager of American Century | Co-Portfolio Manager | 2010 | |||
Jeffrey Houston, CFA | Vice President and Senior Portfolio Manager of American Century | Co-Portfolio Manager | 2010 | |||
Brian Howell | Vice President and Senior Portfolio Manager of American Century | Co-Portfolio Manager | 2010 |
18 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Charles Tan | Senior Vice President and Co-Chief Investment Officer, Global Fixed Income of American Century (Global Macro Strategy Team Representative) | Co-Portfolio Manager | 2018 |
Prospectus 2020 | 19 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $79 | $246 | $428 | $954 |
Class 2 (whether or not shares are redeemed) | $104 | $325 | $563 | $1,248 |
20 | Prospectus 2020 |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 16.22% |
Worst
|
3rd Quarter 2011 | -20.22% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 26.41% | 5.64% | 8.27% |
Class 2 | 05/07/2010 | 26.16% | 5.39% | 7.99% |
FTSE Nareit Equity REITs Index (reflects no deductions for fees, expenses or taxes) | 26.00% | 7.21% | 11.25% |
Prospectus 2020 | 23 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Dean Frankel, CFA | Managing Director, Head of Real Estate Securities of CenterSquare | Co-Portfolio Manager | 2016 | |||
Eric Rothman, CFA | Portfolio Manager of CenterSquare | Co-Portfolio Manager | 2016 |
24 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $70 | $221 | $384 | $859 |
Class 2 (whether or not shares are redeemed) | $96 | $300 | $520 | $1,155 |
Prospectus 2020 | 25 |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 15.98% |
Worst
|
3rd Quarter 2011 | -14.92% |
28 | Prospectus 2020 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 31.76% | 14.89% | 14.69% |
Class 2 | 05/07/2010 | 31.43% | 14.60% | 14.41% |
Russell 1000 Growth Index (reflects no deductions for fees, expenses or taxes) | 36.39% | 14.63% | 15.92% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Aziz Hamzaogullari, CFA | Executive Vice President, Chief Investment Officer and Founder of the Growth Equity Strategies Team, and Portfolio Manager of Loomis Sayles | Portfolio Manager | 2014 |
Prospectus 2020 | 29 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $70 | $221 | $384 | $859 |
Class 2 (whether or not shares are redeemed) | $96 | $300 | $520 | $1,155 |
30 | Prospectus 2020 |
Prospectus 2020 | 31 |
32 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2012 | 17.43% |
Worst
|
3rd Quarter 2011 | -15.40% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 32.61% | 12.27% | 13.81% |
Class 2 | 05/07/2010 | 32.28% | 11.99% | 13.52% |
Russell 1000 Growth Index (reflects no deductions for fees, expenses or taxes) | 36.39% | 14.63% | 15.92% |
Prospectus 2020 | 33 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Thomas Stevens, CFA | Chairman, CEO and Senior Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 | |||
Hal Reynolds, CFA | Chief Investment Officer and Senior Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 | |||
Daniel Allen, CFA | President and Senior Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 | |||
Daniel Arche, CFA | Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 |
34 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $72 | $224 | $390 | $871 |
Class 2 (whether or not shares are redeemed) | $97 | $303 | $525 | $1,166 |
Prospectus 2020 | 35 |
36 | Prospectus 2020 |
Prospectus 2020 | 37 |
38 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 12.78% |
Worst
|
3rd Quarter 2011 | -15.34% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 29.83% | 9.23% | 11.73% |
Class 2 | 05/07/2010 | 29.51% | 8.96% | 11.45% |
Russell 1000 Value Index (reflects no deductions for fees, expenses or taxes) | 26.54% | 8.29% | 12.01% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Katherine Cannan | Investment Officer and Portfolio Manager of MFS | Co-Portfolio Manager | December 2019 | |||
Nevin Chitkara | Investment Officer and Portfolio Manager of MFS | Co-Portfolio Manager | 2010 | |||
Steve Gorham* | Investment Officer and Portfolio Manager of MFS | Co-Portfolio Manager | 2010 |
Prospectus 2020 | 39 |
40 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $67 | $211 | $368 | $822 |
Class 2 (whether or not shares are redeemed) | $93 | $290 | $504 | $1,120 |
Prospectus 2020 | 41 |
42 | Prospectus 2020 |
Prospectus 2020 | 43 |
44 | Prospectus 2020 |
Prospectus 2020 | 45 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 27.17% | 13.84% | 14.05% |
Class 2 | 05/07/2010 | 26.85% | 13.55% | 13.76% |
Russell 1000 Growth Index (reflects no deductions for fees, expenses or taxes) | 36.39% | 14.63% | 15.92% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Dennis Lynch | Managing Director and Investor of MSIM | Lead Portfolio Manager | 2016 | |||
Sam Chainani, CFA | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
Jason Yeung, CFA | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
Armistead Nash | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
David Cohen | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
Alexander Norton | Executive Director and Investor of MSIM | Portfolio Manager | 2016 |
46 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $70 | $221 | $384 | $859 |
Class 2 (whether or not shares are redeemed) | $96 | $300 | $520 | $1,155 |
Prospectus 2020 | 47 |
48 | Prospectus 2020 |
Prospectus 2020 | 49 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 4th Quarter 2011 | 12.17% |
Worst
|
3rd Quarter 2011 | -14.11% |
50 | Prospectus 2020 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 26.58% | 6.98% | 10.49% |
Class 2 | 05/07/2010 | 26.22% | 6.70% | 10.21% |
Russell 1000 Value Index (reflects no deductions for fees, expenses or taxes) | 26.54% | 8.29% | 12.01% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Heather McPherson |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | 2016 | |||
Mark Finn, CFA, CPA |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | 2016 | |||
John Linehan, CFA |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | 2016 |
Prospectus 2020 | 51 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $50 | $157 | $274 | $616 |
Class 2 (whether or not shares are redeemed) | $76 | $237 | $411 | $918 |
52 | Prospectus 2020 |
Prospectus 2020 | 53 |
54 | Prospectus 2020 |
Prospectus 2020 | 55 |
56 | Prospectus 2020 |
Prospectus 2020 | 57 |
58 | Prospectus 2020 |
Prospectus 2020 | 59 |
60 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 2nd Quarter 2019 | 3.11% |
Worst
|
4th Quarter 2016 | -2.79% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 9.01% | 2.96% | 3.02% |
Class 2 | 05/07/2010 | 8.58% | 2.70% | 2.76% |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Tad Rivelle | Group Managing Director and Chief Investment Officer – Fixed Income of TCW since December 2009 | Co-Portfolio Manager | 2014 | |||
Laird Landmann | Co-Director of Fixed Income and Group Managing Director of TCW | Co-Portfolio Manager | 2014 | |||
Stephen Kane, CFA | Group Managing Director of TCW | Co-Portfolio Manager | 2014 | |||
Bryan Whalen, CFA | Group Managing Director of TCW | Co-Portfolio Manager | 2014 |
Prospectus 2020 | 61 |
62 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $44 | $138 | $241 | $542 |
Class 2 (whether or not shares are redeemed) | $69 | $218 | $379 | $847 |
Prospectus 2020 | 63 |
64 | Prospectus 2020 |
Prospectus 2020 | 65 |
66 | Prospectus 2020 |
Prospectus 2020 | 67 |
68 | Prospectus 2020 |
Prospectus 2020 | 69 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 2nd Quarter 2019 | 1.31% |
Worst
|
2nd Quarter 2013 | -0.69% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 3.57% | 1.33% | 1.40% |
Class 2 | 05/07/2010 | 3.33% | 1.08% | 1.14% |
Bloomberg Barclays U.S. 1-3 Year Government Bond Index (reflects no deductions for fees, expenses or taxes) | 3.59% | 1.40% | 1.17% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Thomas O’Connor, CFA* | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2010 | |||
Maulik Bhansali, CFA | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 | |||
Jarad Vasquez | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 |
* | Mr. O’Connor has announced his intention to retire from WellsCap effective December 31, 2020. Accordingly, after December 31, 2020, all references to Mr. O’Connor are hereby removed. |
70 | Prospectus 2020 |
Prospectus 2020 | 71 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $85 | $265 | $460 | $1,025 |
Class 2 (whether or not shares are redeemed) | $110 | $343 | $595 | $1,317 |
72 | Prospectus 2020 |
Prospectus 2020 | 73 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 21.15% |
Worst
|
4th Quarter 2018 | -15.79% |
74 | Prospectus 2020 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 42.14% | 11.23% | 12.87% |
Class 2 | 05/07/2010 | 41.80% | 10.96% | 12.58% |
Russell Midcap Growth Index (reflects no deductions for fees, expenses or taxes) | 35.47% | 11.60% | 14.49% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
William Muggia | President, Chief Executive Officer, Chief Investment Officer and Managing Partner of Westfield | Co-Portfolio Manager | 2017 | |||
Richard Lee, CFA | Deputy Chief Investment Officer and Managing Partner of Westfield | Co-Portfolio Manager | 2017 | |||
Ethan Meyers, CFA | Director of Research and Managing Partner of Westfield | Co-Portfolio Manager | 2017 |
Prospectus 2020 | 75 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $49 | $154 | $269 | $604 |
Class 2 (whether or not shares are redeemed) | $75 | $233 | $406 | $906 |
76 | Prospectus 2020 |
Prospectus 2020 | 77 |
78 | Prospectus 2020 |
Prospectus 2020 | 79 |
80 | Prospectus 2020 |
Prospectus 2020 | 81 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 8.61% | 3.05% | 3.50% |
Class 2 | 05/07/2010 | 8.39% | 2.78% | 3.24% |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Richard Figuly | Managing Director and Portfolio Manager of JPMIM | Co-Portfolio Manager | 2016 | |||
Justin Rucker | Executive Director and Portfolio Manager of JPMIM | Co-Portfolio Manager | 2019 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Thomas O’Connor, CFA* | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 | |||
Maulik Bhansali, CFA | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 | |||
Jarad Vasquez | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 |
* | Mr. O’Connor has announced his intention to retire from WellsCap effective December 31, 2020. Accordingly, after December 31, 2020, all references to Mr. O’Connor are hereby removed. |
82 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $81 | $252 | $439 | $978 |
Class 2 (whether or not shares are redeemed) | $106 | $331 | $574 | $1,271 |
Prospectus 2020 | 83 |
84 | Prospectus 2020 |
Prospectus 2020 | 85 |
86 | Prospectus 2020 |
Prospectus 2020 | 87 |
88 | Prospectus 2020 |
Prospectus 2020 | 89 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 18.76% | 3.20% | 5.18% |
Class 2 | 05/07/2010 | 18.41% | 2.95% | 4.91% |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 5.67% | 6.98% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Michele Aghassi, Ph.D. | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | 2018 | |||
Andrea Frazzini, Ph.D. | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | 2018 | |||
Ronen Israel | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | January 2020 | |||
Lars Nielsen | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | January 2020 |
90 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.92% for Class 1 and 1.17% for Class 2. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $94 | $295 | $514 | $1,142 |
Class 2 (whether or not shares are redeemed) | $119 | $374 | $648 | $1,431 |
Prospectus 2020 | 91 |
92 | Prospectus 2020 |
Prospectus 2020 | 93 |
94 | Prospectus 2020 |
Prospectus 2020 | 95 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 10.85% |
Worst
|
3rd Quarter 2011 | -17.94% |
96 | Prospectus 2020 |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 26.70% | 4.21% | 6.58% |
Class 2 | 05/07/2010 | 26.36% | 3.97% | 6.32% |
MSCI EAFE Growth Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 27.90% | 7.71% | 8.28% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Simon Fennell | Partner of William Blair | Co-Portfolio Manager | May 2019 | |||
Kenneth McAtamney | Partner of William Blair | Co-Portfolio Manager | May 2019 |
Prospectus 2020 | 97 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.84% for Class 1 and 1.09% for Class 2. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $86 | $277 | $484 | $1,081 |
Class 2 (whether or not shares are redeemed) | $111 | $355 | $618 | $1,371 |
98 | Prospectus 2020 |
Prospectus 2020 | 99 |
100 | Prospectus 2020 |
Prospectus 2020 | 101 |
102 | Prospectus 2020 |
Prospectus 2020 | 103 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 3rd Quarter 2013 | 13.61% |
Worst
|
3rd Quarter 2011 | -23.98% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 13.53% | 3.39% | 3.59% |
Class 2 | 05/07/2010 | 13.20% | 3.13% | 3.33% |
MSCI EAFE Value Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 16.09% | 3.54% | 5.59% |
104 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jed Fogdall | Global Head of Portfolio Management, Chairman of the Investment Committee, Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | 2011 | |||
Arun Keswani, CFA | Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | May 2020 | |||
Mary Phillips, CFA | Deputy Head of Portfolio Management, North America, member of the Investment Committee, Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | 2015 | |||
Bhanu Singh | Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | 2015 |
Prospectus 2020 | 105 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
(b) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.87% for Class 1 and 1.12% for Class 2. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $89 | $280 | $487 | $1,083 |
Class 2 (whether or not shares are redeemed) | $114 | $358 | $621 | $1,374 |
106 | Prospectus 2020 |
Prospectus 2020 | 107 |
108 | Prospectus 2020 |
Prospectus 2020 | 109 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 15.53% |
Worst
|
4th Quarter 2018 | -22.22% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 05/07/2010 | 21.26% | 6.82% | 10.13% |
Class 2 | 05/07/2010 | 20.95% | 6.55% | 9.85% |
Russell 2000 Growth Index (reflects no deductions for fees, expenses or taxes) | 28.48% | 9.34% | 13.21% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David Corris, CFA | Portfolio Manager of BMO | Co-Portfolio Manager | 2017 | |||
Thomas Lettenberger, CFA | Portfolio Manager of BMO | Co-Portfolio Manager | 2017 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
James McBride, CFA | Portfolio Manager of Scout | Lead Portfolio Manager | May 2019 | |||
Timothy Miller, CFA | Portfolio Manager of Scout | Co-Portfolio Manager | May 2019 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Joseph Eberhardy, CFA, CPA | Portfolio Manager of WellsCap | Co-Portfolio Manager | 2010 | |||
Thomas Ognar, CFA | Portfolio Manager of WellsCap | Co-Portfolio Manager | 2010 |
110 | Prospectus 2020 |
Prospectus 2020 | 111 |
■ | Emphasizing an independent, proprietary credit research process of issuers of debt securities; |
■ | Analyzing issuer-specific inputs, such as business strategy, management strength, competitive position and various financial metrics to identify the most attractive securities within each industry; |
■ | Investing opportunistically in lower-quality (junk) bonds based on relative valuations and risk-adjusted return expectations; |
■ | Utilizing quantitative risk controls and qualitative risk assessments in a framework that seeks to minimize issuer credit risk. |
■ | Change in an issuer’s credit fundamentals relative to the Fund investment team’s expectations; |
■ | Changes to the fundamental attractiveness of a sector, industry group, or security; |
■ | Changes to the risk/reward trade-off of an issuer; |
■ | The potential development of event risk; |
■ | Adjustments needed to change overall portfolio risk. |
112 | Prospectus 2020 |
Prospectus 2020 | 113 |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
114 | Prospectus 2020 |
Prospectus 2020 | 115 |
116 | Prospectus 2020 |
Prospectus 2020 | 117 |
118 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Tom Murphy, CFA | Vice President, Senior Portfolio Manager and Head of Investment Grade Credit | Lead Portfolio Manager | 2010 | |||
Royce D. Wilson, CFA | Senior Portfolio Manager | Portfolio Manager | 2012 | |||
John Dawson, CFA | Portfolio Manager | Portfolio Manager | February 2020 |
Prospectus 2020 | 119 |
■ | the desired maturity requirements for the portfolio; |
■ | the portfolio’s credit quality standards; |
■ | current and anticipated interest rates; |
■ | current economic conditions and the risk of inflation; and/or |
■ | special features of the debt securities that may make them more or less attractive. |
120 | Prospectus 2020 |
Prospectus 2020 | 121 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). |
122 | Prospectus 2020 |
Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or |
Prospectus 2020 | 123 |
otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
124 | Prospectus 2020 |
Prospectus 2020 | 125 |
126 | Prospectus 2020 |
Prospectus 2020 | 127 |
128 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Robert Gahagan | Senior Vice President and Senior Portfolio Manager of American Century (Global Macro Strategy Team Representative) | Co-Portfolio Manager | 2010 | |||
Alejandro Aguilar, CFA | Vice President and Senior Portfolio Manager of American Century | Co-Portfolio Manager | 2010 | |||
Jeffrey Houston, CFA | Vice President and Senior Portfolio Manager of American Century | Co-Portfolio Manager | 2010 | |||
Brian Howell | Vice President and Senior Portfolio Manager of American Century | Co-Portfolio Manager | 2010 | |||
Charles Tan | Senior Vice President and Co-Chief Investment Officer, Global Fixed Income of American Century (Global Macro Strategy Team Representative) | Co-Portfolio Manager | 2018 |
Prospectus 2020 | 129 |
130 | Prospectus 2020 |
■ | Monitors factors such as real estate trends and industry fundamentals of real estate sectors including office, apartment, retail, hotel, and industrial. |
■ | Selects stocks by evaluating each company’s real estate value, quality of its assets, and management record for improving earnings and increasing asset value relative to other publicly traded real estate companies. |
■ | Sells all or part of the Fund’s holdings in a particular security if CenterSquare believes: |
■ | The security appreciates to a premium relative to other real estate companies; or |
■ | The anticipated return is not sufficient compared with the risk of continued ownership. |
Prospectus 2020 | 131 |
132 | Prospectus 2020 |
Prospectus 2020 | 133 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Dean Frankel, CFA | Managing Director, Head of Real Estate Securities of CenterSquare | Co-Portfolio Manager | 2016 | |||
Eric Rothman, CFA | Portfolio Manager of CenterSquare | Co-Portfolio Manager | 2016 |
134 | Prospectus 2020 |
Prospectus 2020 | 135 |
136 | Prospectus 2020 |
Prospectus 2020 | 137 |
138 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Aziz Hamzaogullari, CFA | Executive Vice President, Chief Investment Officer and Founder of the Growth Equity Strategies Team, and Portfolio Manager of Loomis Sayles | Portfolio Manager | 2014 |
Prospectus 2020 | 139 |
140 | Prospectus 2020 |
Prospectus 2020 | 141 |
142 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Thomas Stevens, CFA | Chairman, CEO and Senior Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 | |||
Hal Reynolds, CFA | Chief Investment Officer and Senior Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 |
Prospectus 2020 | 143 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Daniel Allen, CFA | President and Senior Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 | |||
Daniel Arche, CFA | Portfolio Manager of Los Angeles Capital | Co-Portfolio Manager | 2017 |
144 | Prospectus 2020 |
Prospectus 2020 | 145 |
146 | Prospectus 2020 |
Prospectus 2020 | 147 |
148 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Katherine Cannan | Investment Officer and Portfolio Manager of MFS | Co-Portfolio Manager | December 2019 | |||
Nevin Chitkara | Investment Officer and Portfolio Manager of MFS | Co-Portfolio Manager | 2010 | |||
Steve Gorham* | Investment Officer and Portfolio Manager of MFS | Co-Portfolio Manager | 2010 |
Prospectus 2020 | 149 |
150 | Prospectus 2020 |
Prospectus 2020 | 151 |
152 | Prospectus 2020 |
Prospectus 2020 | 153 |
154 | Prospectus 2020 |
Prospectus 2020 | 155 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Dennis Lynch | Managing Director and Investor of MSIM | Lead Portfolio Manager | 2016 | |||
Sam Chainani, CFA | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
Jason Yeung, CFA | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
Armistead Nash | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
David Cohen | Managing Director and Investor of MSIM | Portfolio Manager | 2016 | |||
Alexander Norton | Executive Director and Investor of MSIM | Portfolio Manager | 2016 |
156 | Prospectus 2020 |
■ | low price/earnings, price/book value, price/sales, or price/cash flow ratios relative to the broader equity market, the company’s peers, or its own historical norm; |
■ | low stock price relative to a company’s underlying asset values; |
■ | companies that may benefit from restructuring activity; |
■ | a sound balance sheet and other positive financial characteristics; and/or |
■ | fundamental or other factors or reasons, including an extraordinary corporate event, a new product introduction or innovation, a favorable competitive development, or a change in management. |
Prospectus 2020 | 157 |
158 | Prospectus 2020 |
Prospectus 2020 | 159 |
160 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Heather McPherson |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | 2016 | |||
Mark Finn, CFA, CPA |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | 2016 | |||
John Linehan, CFA |
Vice President and Portfolio Manager of
T. Rowe Price |
Co-Portfolio Manager | 2016 |
Prospectus 2020 | 161 |
162 | Prospectus 2020 |
Prospectus 2020 | 163 |
164 | Prospectus 2020 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
Prospectus 2020 | 165 |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
166 | Prospectus 2020 |
Prospectus 2020 | 167 |
168 | Prospectus 2020 |
Prospectus 2020 | 169 |
170 | Prospectus 2020 |
Prospectus 2020 | 171 |
172 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Tad Rivelle | Group Managing Director and Chief Investment Officer – Fixed Income of TCW since December 2009 | Co-Portfolio Manager | 2014 | |||
Laird Landmann | Co-Director of Fixed Income and Group Managing Director of TCW | Co-Portfolio Manager | 2014 | |||
Stephen Kane, CFA | Group Managing Director of TCW | Co-Portfolio Manager | 2014 | |||
Bryan Whalen, CFA | Group Managing Director of TCW | Co-Portfolio Manager | 2014 |
Prospectus 2020 | 173 |
174 | Prospectus 2020 |
■ | offer competitive returns; |
■ | are undervalued; and/or |
■ | offer additional income and/or price appreciation potential relative to other debt securities of similar credit quality and interest rate sensitivity. |
■ | The security has achieved its designed return; |
■ | The security or its sector has become overvalued; and/or |
■ | A more attractive opportunity becomes available or the security is no longer attractive due to its risk profile or as a result of changes in the overall market environment. |
Prospectus 2020 | 175 |
176 | Prospectus 2020 |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
Prospectus 2020 | 177 |
178 | Prospectus 2020 |
Prospectus 2020 | 179 |
180 | Prospectus 2020 |
Prospectus 2020 | 181 |
182 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Thomas O’Connor, CFA* | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2010 | |||
Maulik Bhansali, CFA | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 | |||
Jarad Vasquez | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 |
* | Mr. O’Connor has announced his intention to retire from WellsCap effective December 31, 2020. Accordingly, after December 31, 2020, all references to Mr. O’Connor are hereby removed. |
Prospectus 2020 | 183 |
184 | Prospectus 2020 |
Prospectus 2020 | 185 |
186 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
William Muggia | President, Chief Executive Officer, Chief Investment Officer and Managing Partner of Westfield | Co-Portfolio Manager | 2017 | |||
Richard Lee, CFA | Deputy Chief Investment Officer and Managing Partner of Westfield | Co-Portfolio Manager | 2017 | |||
Ethan Meyers, CFA | Director of Research and Managing Partner of Westfield | Co-Portfolio Manager | 2017 |
Prospectus 2020 | 187 |
■ | identifying securities that it believes are priced inefficiently; |
■ | making sector allocation decisions based on a broad sector outlook, utilizing expected return and valuation analysis; |
■ | managing the yield curve, with an emphasis on evaluating relative risk/reward relationships along the yield curve; and |
■ | managing portfolio duration, primarily as a risk control measure. |
188 | Prospectus 2020 |
Prospectus 2020 | 189 |
190 | Prospectus 2020 |
Prospectus 2020 | 191 |
192 | Prospectus 2020 |
Prospectus 2020 | 193 |
194 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Richard Figuly | Managing Director and Portfolio Manager of JPMIM | Co-Portfolio Manager | 2016 | |||
Justin Rucker | Executive Director and Portfolio Manager of JPMIM | Co-Portfolio Manager | 2019 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Thomas O’Connor, CFA* | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 | |||
Maulik Bhansali, CFA | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 | |||
Jarad Vasquez | Senior Portfolio Manager of WellsCap | Co-Portfolio Manager | 2017 |
* | Mr. O’Connor has announced his intention to retire from WellsCap effective December 31, 2020. Accordingly, after December 31, 2020, all references to Mr. O’Connor are hereby removed. |
Prospectus 2020 | 195 |
■ | Value strategies favor securities that appear relatively inexpensive based on fundamental measures. Examples of value strategies include using price-to-earnings and price-to-book ratios. |
■ | Momentum strategies favor securities with strong recent performance and positive changes in fundamentals. |
196 | Prospectus 2020 |
Prospectus 2020 | 197 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency strategy by a Fund may be reduced by the Fund's inability to precisely match forward contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
198 | Prospectus 2020 |
Prospectus 2020 | 199 |
200 | Prospectus 2020 |
Prospectus 2020 | 201 |
202 | Prospectus 2020 |
Prospectus 2020 | 203 |
204 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Michele Aghassi, Ph.D. | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | 2018 | |||
Andrea Frazzini, Ph.D. | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | 2018 | |||
Ronen Israel | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | January 2020 | |||
Lars Nielsen | Portfolio Manager and Principal of AQR | Co-Portfolio Manager | January 2020 |
Prospectus 2020 | 205 |
206 | Prospectus 2020 |
Prospectus 2020 | 207 |
208 | Prospectus 2020 |
Prospectus 2020 | 209 |
210 | Prospectus 2020 |
Prospectus 2020 | 211 |
212 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Simon Fennell | Partner of William Blair | Co-Portfolio Manager | May 2019 | |||
Kenneth McAtamney | Partner of William Blair | Co-Portfolio Manager | May 2019 |
Prospectus 2020 | 213 |
214 | Prospectus 2020 |
Prospectus 2020 | 215 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
216 | Prospectus 2020 |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
Prospectus 2020 | 217 |
218 | Prospectus 2020 |
Prospectus 2020 | 219 |
220 | Prospectus 2020 |
Prospectus 2020 | 221 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Jed Fogdall | Global Head of Portfolio Management, Chairman of the Investment Committee, Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | 2011 | |||
Arun Keswani, CFA | Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | May 2020 | |||
Mary Phillips, CFA | Deputy Head of Portfolio Management, North America, member of the Investment Committee, Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | 2015 | |||
Bhanu Singh | Vice President and Senior Portfolio Manager of DFA | Co-Portfolio Manager | 2015 |
222 | Prospectus 2020 |
■ | Companies that are undervalued relative to their fundamentals and exhibit improving investor interest outperform the market over the long run |
■ | A systematic approach to stock evaluation and portfolio construction maximizes risk-adjusted returns over full market cycles |
Prospectus 2020 | 223 |
224 | Prospectus 2020 |
Prospectus 2020 | 225 |
226 | Prospectus 2020 |
Prospectus 2020 | 227 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David Corris, CFA | Portfolio Manager of BMO | Co-Portfolio Manager | 2017 | |||
Thomas Lettenberger, CFA | Portfolio Manager of BMO | Co-Portfolio Manager | 2017 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
James McBride, CFA | Portfolio Manager of Scout | Lead Portfolio Manager | May 2019 | |||
Timothy Miller, CFA | Portfolio Manager of Scout | Co-Portfolio Manager | May 2019 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Joseph Eberhardy, CFA, CPA | Portfolio Manager of WellsCap | Co-Portfolio Manager | 2010 | |||
Thomas Ognar, CFA | Portfolio Manager of WellsCap | Co-Portfolio Manager | 2010 |
228 | Prospectus 2020 |
Prospectus 2020 | 229 |
230 | Prospectus 2020 |
Prospectus 2020 | 231 |
Class 1 | Class 2 | |
Columbia VP - Limited Duration Credit Fund | 0.49% | 0.74% |
CTIVP® - CenterSquare Real Estate Fund | 0.89% | 1.14% |
CTIVP® - Loomis Sayles Growth Fund | 0.74% | 0.99% |
CTIVP® - Los Angeles Capital Large Cap Growth Fund | 0.73% | 0.98% |
CTIVP® - MFS® Value Fund | 0.72% | 0.97% |
CTIVP® - Morgan Stanley Advantage Fund | 0.74% | 0.99% |
CTIVP® - T. Rowe Price Large Cap Value Fund | 0.71% | 0.96% |
CTIVP® - TCW Core Plus Bond Fund | 0.54% | 0.79% |
CTIVP® - Wells Fargo Short Duration Government Fund | 0.46% | 0.71% |
CTIVP® - Westfield Mid Cap Growth Fund | 0.85% | 1.10% |
VP - Partners International Core Equity Fund | 0.88% | 1.13% |
VP - Partners International Growth Fund | 0.92% | 1.17% |
VP - Partners International Value Fund | 0.84% | 1.09% |
232 | Prospectus 2020 |
Class 1 | Class 2 | |
VP - Partners Small Cap Growth Fund | 0.87% | 1.12% |
Class 1 | Class 2 | |
CTIVP® - American Century Diversified Bond Fund | 0.56% | 0.81% |
VP - Partners Core Bond Fund | 0.56% | 0.81% |
Prospectus 2020 | 233 |
Management fee
for the fiscal year ended December 31, 2019 |
|
Columbia VP - Limited Duration Credit Fund | 0.48% |
CTIVP® - American Century Diversified Bond Fund | 0.49% |
CTIVP® - CenterSquare Real Estate Fund | 0.75% |
CTIVP® - Loomis Sayles Growth Fund | 0.66% |
CTIVP® - Los Angeles Capital Large Cap Growth Fund | 0.68% |
CTIVP® - MFS® Value Fund | 0.69% |
CTIVP® - Morgan Stanley Advantage Fund | 0.65% |
CTIVP® - T. Rowe Price Large Cap Value Fund | 0.68% |
CTIVP® - TCW Core Plus Bond Fund | 0.48% |
CTIVP® - Wells Fargo Short Duration Government Fund | 0.42% |
CTIVP® - Westfield Mid Cap Growth Fund | 0.81% |
VP - Partners Core Bond Fund | 0.47% |
234 | Prospectus 2020 |
Management fee
for the fiscal year ended December 31, 2019 |
|
VP - Partners International Core Equity Fund | 0.77% |
VP - Partners International Growth Fund | 0.90% |
VP - Partners International Value Fund | 0.85% |
VP - Partners Small Cap Growth Fund | 0.86% |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
Prospectus 2020 | 235 |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
236 | Prospectus 2020 |
Class 1 Shares | Class 2 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | |
Investment Limits | none | none |
Conversion Features | none | none |
Front-End Sales Charges | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% |
Prospectus 2020 | 237 |
238 | Prospectus 2020 |
Prospectus 2020 | 239 |
240 | Prospectus 2020 |
Prospectus 2020 | 241 |
242 | Prospectus 2020 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
Prospectus 2020 | 243 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. |
RIC Fund | Declarations | Distributions |
Columbia VP - Limited Duration Credit Fund | Annually | Annually |
CTIVP® - American Century Diversified Bond Fund | Annually | Annually |
CTIVP® - CenterSquare Real Estate Fund | Annually | Annually |
CTIVP® - TCW Core Plus Bond Fund | Annually | Annually |
CTIVP® - Wells Fargo Short Duration Government Fund | Annually | Annually |
VP - Partners Core Bond Fund | Annually | Annually |
VP - Partners International Core Equity Fund | Quarterly | Quarterly |
VP - Partners International Growth Fund | Quarterly | Quarterly |
VP - Partners International Value Fund | Quarterly | Quarterly |
244 | Prospectus 2020 |
Prospectus 2020 | 245 |
246 | Prospectus 2020 |
Prospectus 2020 | 247 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Total
distributions to shareholders |
|
Class 1 | ||||||
Year Ended 12/31/2019 | $9.28 | 0.25 | 0.46 | 0.71 | (0.23) | (0.23) |
Year Ended 12/31/2018 | $9.44 | 0.21 | (0.19) | 0.02 | (0.18) | (0.18) |
Year Ended 12/31/2017 | $9.47 | 0.17 | 0.02 | 0.19 | (0.22) | (0.22) |
Year Ended 12/31/2016 | $9.34 | 0.20 | 0.31 | 0.51 | (0.38) | (0.38) |
Year Ended 12/31/2015 | $10.12 | 0.25 | (0.47) | (0.22) | (0.56) | (0.56) |
Class 2 | ||||||
Year Ended 12/31/2019 | $9.24 | 0.22 | 0.47 | 0.69 | (0.21) | (0.21) |
Year Ended 12/31/2018 | $9.40 | 0.19 | (0.19) | 0.00(c) | (0.16) | (0.16) |
Year Ended 12/31/2017 | $9.43 | 0.15 | 0.02 | 0.17 | (0.20) | (0.20) |
Year Ended 12/31/2016 | $9.30 | 0.17 | 0.32 | 0.49 | (0.36) | (0.36) |
Year Ended 12/31/2015 | $10.07 | 0.22 | (0.45) | (0.23) | (0.54) | (0.54) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
248 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.76 | 7.69% | 0.50% | 0.49% | 2.58% | 110% | $684,486 |
Year Ended 12/31/2018 | $9.28 | 0.24% | 0.50% | 0.50% | 2.30% | 62% | $707,421 |
Year Ended 12/31/2017 | $9.44 | 2.05% | 0.53% | 0.53% | 1.79% | 104% | $773,190 |
Year Ended 12/31/2016 | $9.47 | 5.53% | 0.55% | 0.55% | 2.14% | 102% | $845,695 |
Year Ended 12/31/2015 | $9.34 | (2.31%) | 0.54% | 0.54% | 2.46% | 78% | $887,028 |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.72 | 7.47% | 0.75% | 0.74% | 2.32% | 110% | $54,988 |
Year Ended 12/31/2018 | $9.24 | (0.02%) | 0.75% | 0.75% | 2.06% | 62% | $46,253 |
Year Ended 12/31/2017 | $9.40 | 1.80% | 0.78% | 0.78% | 1.55% | 104% | $40,342 |
Year Ended 12/31/2016 | $9.43 | 5.28% | 0.81% | 0.80% | 1.85% | 102% | $35,554 |
Year Ended 12/31/2015 | $9.30 | (2.49%) | 0.80% | 0.79% | 2.29% | 78% | $22,577 |
Prospectus 2020 | 249 |
Prospectus 2020 | 251 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.65 | 0.31 | 0.71 | 1.02 | (0.66) | — | (0.66) |
Year Ended 12/31/2018 | $11.15 | 0.37 | (0.49) | (0.12) | (0.31) | (0.07) | (0.38) |
Year Ended 12/31/2017 | $10.95 | 0.30 | 0.23 | 0.53 | (0.26) | (0.07) | (0.33) |
Year Ended 12/31/2016 | $10.76 | 0.27 | 0.13 | 0.40 | (0.20) | (0.01) | (0.21) |
Year Ended 12/31/2015 | $11.05 | 0.23 | (0.23) | 0.00(d) | (0.24) | (0.05) | (0.29) |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.61 | 0.28 | 0.70 | 0.98 | (0.63) | — | (0.63) |
Year Ended 12/31/2018 | $11.11 | 0.34 | (0.49) | (0.15) | (0.28) | (0.07) | (0.35) |
Year Ended 12/31/2017 | $10.91 | 0.27 | 0.23 | 0.50 | (0.23) | (0.07) | (0.30) |
Year Ended 12/31/2016 | $10.72 | 0.24 | 0.13 | 0.37 | (0.17) | (0.01) | (0.18) |
Year Ended 12/31/2015 | $11.01 | 0.20 | (0.22) | (0.02) | (0.22) | (0.05) | (0.27) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interest on collateral expense which is less than 0.01%. |
(d) | Rounds to zero. |
252 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $11.01 | 9.73% | 0.50% (c) | 0.50% (c) | 2.84% | 94% | $2,900,664 |
Year Ended 12/31/2018 | $10.65 | (1.05%) | 0.48% (c) | 0.48% (c) | 3.42% | 136% | $1,992,309 |
Year Ended 12/31/2017 | $11.15 | 4.89% | 0.52% | 0.52% | 2.74% | 142% | $3,933,591 |
Year Ended 12/31/2016 | $10.95 | 3.66% | 0.55% | 0.55% | 2.42% | 170% | $4,086,952 |
Year Ended 12/31/2015 | $10.76 | 0.05% | 0.55% | 0.55% | 2.07% | 223% | $4,256,477 |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.96 | 9.40% | 0.75% (c) | 0.75% (c) | 2.58% | 94% | $18,712 |
Year Ended 12/31/2018 | $10.61 | (1.31%) | 0.73% (c) | 0.73% (c) | 3.17% | 136% | $13,100 |
Year Ended 12/31/2017 | $11.11 | 4.65% | 0.77% | 0.77% | 2.50% | 142% | $11,701 |
Year Ended 12/31/2016 | $10.91 | 3.42% | 0.80% | 0.80% | 2.18% | 170% | $10,346 |
Year Ended 12/31/2015 | $10.72 | (0.20%) | 0.80% | 0.80% | 1.83% | 223% | $7,924 |
Prospectus 2020 | 253 |
Prospectus 2020 | 255 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $7.94 | 0.19 | 1.89 | 2.08 | (0.17) | — | (0.17) |
Year Ended 12/31/2018 | $8.64 | 0.17 | (0.64) | (0.47) | (0.16) | (0.07) | (0.23) |
Year Ended 12/31/2017 | $8.59 | 0.17 | 0.33 | 0.50 | (0.19) | (0.26) | (0.45) |
Year Ended 12/31/2016 | $8.83 | 0.19 | 0.28(c) | 0.47 | (0.17) | (0.54) | (0.71) |
Year Ended 12/31/2015 | $11.26 | 0.17 | (0.31) | (0.14) | (0.76) | (1.53) | (2.29) |
Class 2 | |||||||
Year Ended 12/31/2019 | $7.89 | 0.17 | 1.88 | 2.05 | (0.15) | — | (0.15) |
Year Ended 12/31/2018 | $8.59 | 0.15 | (0.64) | (0.49) | (0.14) | (0.07) | (0.21) |
Year Ended 12/31/2017 | $8.54 | 0.15 | 0.32 | 0.47 | (0.16) | (0.26) | (0.42) |
Year Ended 12/31/2016 | $8.78 | 0.16 | 0.29(c) | 0.45 | (0.15) | (0.54) | (0.69) |
Year Ended 12/31/2015 | $11.20 | 0.15 | (0.31) | (0.16) | (0.73) | (1.53) | (2.26) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Calculation of the net gain (loss) per share (both realized and unrealized) does not correlate to the aggregate realized and unrealized gain (loss) presented in the Statement of Operations due to the timing of subscriptions and redemptions of Fund shares in relation to fluctuations in the market value of the portfolio. |
256 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.85 | 26.41% | 0.77% | 0.77% | 2.05% | 70% | $508,863 |
Year Ended 12/31/2018 | $7.94 | (5.58%) | 0.77% | 0.77% | 2.03% | 51% | $402,354 |
Year Ended 12/31/2017 | $8.64 | 6.01% | 0.81% | 0.81% | 2.00% | 72% | $426,287 |
Year Ended 12/31/2016 | $8.59 | 5.02% | 0.89% | 0.88% | 2.16% | 83% | $402,023 |
Year Ended 12/31/2015 | $8.83 | (0.99%) | 1.07% | 1.01% | 1.72% | 27% | $188,580 |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.79 | 26.16% | 1.02% | 1.02% | 1.81% | 70% | $30,302 |
Year Ended 12/31/2018 | $7.89 | (5.85%) | 1.02% | 1.02% | 1.76% | 51% | $24,164 |
Year Ended 12/31/2017 | $8.59 | 5.74% | 1.06% | 1.06% | 1.76% | 72% | $27,353 |
Year Ended 12/31/2016 | $8.54 | 4.76% | 1.17% | 1.15% | 1.82% | 83% | $25,298 |
Year Ended 12/31/2015 | $8.78 | (1.21%) | 1.32% | 1.26% | 1.53% | 27% | $22,032 |
Prospectus 2020 | 257 |
Prospectus 2020 | 259 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $28.50 | 0.17 | 8.88 | 9.05 |
Year Ended 12/31/2018 | $29.20 | 0.17 | (0.87) | (0.70) |
Year Ended 12/31/2017 | $21.95 | 0.10 | 7.15 | 7.25 |
Year Ended 12/31/2016 | $20.75 | 0.15 | 1.05 | 1.20 |
Year Ended 12/31/2015 | $18.76 | 0.12 | 1.87 | 1.99 |
Class 2 | ||||
Year Ended 12/31/2019 | $27.90 | 0.08 | 8.69 | 8.77 |
Year Ended 12/31/2018 | $28.66 | 0.10 | (0.86) | (0.76) |
Year Ended 12/31/2017 | $21.60 | 0.03 | 7.03 | 7.06 |
Year Ended 12/31/2016 | $20.46 | 0.09 | 1.05 | 1.14 |
Year Ended 12/31/2015 | $18.55 | 0.07 | 1.84 | 1.91 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
260 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $37.55 | 31.76% | 0.69% | 0.69% | 0.50% | 7% | $2,504,948 |
Year Ended 12/31/2018 | $28.50 | (2.40%) | 0.70% | 0.70% | 0.57% | 8% | $1,929,781 |
Year Ended 12/31/2017 | $29.20 | 33.03% | 0.72% | 0.72% | 0.39% | 5% | $1,989,749 |
Year Ended 12/31/2016 | $21.95 | 5.78% | 0.73% | 0.73% | 0.72% | 19% | $2,398,329 |
Year Ended 12/31/2015 | $20.75 | 10.61% | 0.75% | 0.75% | 0.60% | 14% | $2,206,011 |
Class 2 | |||||||
Year Ended 12/31/2019 | $36.67 | 31.43% | 0.94% | 0.94% | 0.25% | 7% | $55,206 |
Year Ended 12/31/2018 | $27.90 | (2.65%) | 0.95% | 0.95% | 0.32% | 8% | $44,937 |
Year Ended 12/31/2017 | $28.66 | 32.68% | 0.97% | 0.97% | 0.10% | 5% | $45,101 |
Year Ended 12/31/2016 | $21.60 | 5.57% | 0.98% | 0.98% | 0.41% | 19% | $34,617 |
Year Ended 12/31/2015 | $20.46 | 10.30% | 1.00% | 1.00% | 0.38% | 14% | $6,399 |
Prospectus 2020 | 261 |
Prospectus 2020 | 263 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $26.28 | 0.14 | 8.43 | 8.57 |
Year Ended 12/31/2018 | $26.55 | 0.10 | (0.37) | (0.27) |
Year Ended 12/31/2017 | $20.25 | 0.11 | 6.19 | 6.30 |
Year Ended 12/31/2016 | $20.75 | 0.02 | (0.52) | (0.50) |
Year Ended 12/31/2015 | $19.54 | (0.00) (c) | 1.21 | 1.21 |
Class 2 | ||||
Year Ended 12/31/2019 | $25.71 | 0.06 | 8.24 | 8.30 |
Year Ended 12/31/2018 | $26.04 | 0.03 | (0.36) | (0.33) |
Year Ended 12/31/2017 | $19.91 | 0.04 | 6.09 | 6.13 |
Year Ended 12/31/2016 | $20.44 | (0.03) | (0.50) | (0.53) |
Year Ended 12/31/2015 | $19.31 | (0.05) | 1.18 | 1.13 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
264 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $34.85 | 32.61% | 0.69% | 0.69% | 0.46% | 72% | $2,014,780 |
Year Ended 12/31/2018 | $26.28 | (1.02%) | 0.69% | 0.69% | 0.36% | 95% | $1,569,200 |
Year Ended 12/31/2017 | $26.55 | 31.11% | 0.73% | 0.73% | 0.44% | 145% | $1,593,067 |
Year Ended 12/31/2016 | $20.25 | (2.41%) | 0.77% | 0.77% | 0.10% | 91% | $972,895 |
Year Ended 12/31/2015 | $20.75 | 6.19% | 0.76% | 0.76% | (0.01%) | 64% | $1,453,564 |
Class 2 | |||||||
Year Ended 12/31/2019 | $34.01 | 32.28% | 0.94% | 0.94% | 0.21% | 72% | $14,686 |
Year Ended 12/31/2018 | $25.71 | (1.27%) | 0.94% | 0.94% | 0.12% | 95% | $11,330 |
Year Ended 12/31/2017 | $26.04 | 30.79% | 0.98% | 0.98% | 0.17% | 145% | $9,829 |
Year Ended 12/31/2016 | $19.91 | (2.59%) | 1.02% | 1.02% | (0.15%) | 91% | $7,076 |
Year Ended 12/31/2015 | $20.44 | 5.85% | 1.01% | 1.01% | (0.26%) | 64% | $6,258 |
Prospectus 2020 | 265 |
Prospectus 2020 | 267 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $22.46 | 0.42 | 6.28 | 6.70 |
Year Ended 12/31/2018 | $24.96 | 0.50 | (3.00) | (2.50) |
Year Ended 12/31/2017 | $21.22 | 0.42 | 3.32 | 3.74 |
Year Ended 12/31/2016 | $18.61 | 0.37 | 2.24 | 2.61 |
Year Ended 12/31/2015 | $18.75 | 0.59(d) | (0.73) | (0.14) |
Class 2 | ||||
Year Ended 12/31/2019 | $21.99 | 0.35 | 6.14 | 6.49 |
Year Ended 12/31/2018 | $24.50 | 0.44 | (2.95) | (2.51) |
Year Ended 12/31/2017 | $20.88 | 0.35 | 3.27 | 3.62 |
Year Ended 12/31/2016 | $18.36 | 0.33 | 2.19 | 2.52 |
Year Ended 12/31/2015 | $18.54 | 0.59(e) | (0.77) | (0.18) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interfund lending expense which is less than 0.01%. |
(d) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.28 per share. |
(e) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.33 per share. |
268 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $29.16 | 29.83% | 0.70% (c) | 0.70% (c) | 1.62% | 12% | $1,493,599 |
Year Ended 12/31/2018 | $22.46 | (10.02%) | 0.69% (c) | 0.69% (c) | 2.00% | 8% | $1,588,214 |
Year Ended 12/31/2017 | $24.96 | 17.62% | 0.71% | 0.71% | 1.84% | 13% | $2,203,985 |
Year Ended 12/31/2016 | $21.22 | 14.03% | 0.74% | 0.74% | 1.89% | 23% | $1,995,300 |
Year Ended 12/31/2015 | $18.61 | (0.75%) | 0.73% | 0.73% | 3.14% | 16% | $1,925,986 |
Class 2 | |||||||
Year Ended 12/31/2019 | $28.48 | 29.51% | 0.95% (c) | 0.95% (c) | 1.36% | 12% | $63,976 |
Year Ended 12/31/2018 | $21.99 | (10.25%) | 0.94% (c) | 0.94% (c) | 1.80% | 8% | $45,033 |
Year Ended 12/31/2017 | $24.50 | 17.34% | 0.96% | 0.96% | 1.57% | 13% | $49,410 |
Year Ended 12/31/2016 | $20.88 | 13.73% | 1.00% | 1.00% | 1.71% | 23% | $33,917 |
Year Ended 12/31/2015 | $18.36 | (0.97%) | 0.99% | 0.99% | 3.15% | 16% | $19,747 |
Prospectus 2020 | 269 |
Prospectus 2020 | 271 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $27.97 | (0.02) | 7.62 | 7.60 |
Year Ended 12/31/2018 | $27.18 | 0.02 | 0.77 | 0.79 |
Year Ended 12/31/2017 | $20.50 | (0.01) | 6.69 | 6.68 |
Year Ended 12/31/2016 | $19.85 | 0.08 | 0.57 | 0.65 |
Year Ended 12/31/2015 | $18.60 | 0.71(c) | 0.54 | 1.25 |
Class 2 | ||||
Year Ended 12/31/2019 | $27.37 | (0.10) | 7.45 | 7.35 |
Year Ended 12/31/2018 | $26.67 | (0.06) | 0.76 | 0.70 |
Year Ended 12/31/2017 | $20.17 | (0.06) | 6.56 | 6.50 |
Year Ended 12/31/2016 | $19.57 | 0.03 | 0.57 | 0.60 |
Year Ended 12/31/2015 | $18.39 | 0.59(d) | 0.59 | 1.18 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.64 per share. |
(d) | Net investment income per share includes special dividends. The effect of these dividends amounted to $0.57 per share. |
272 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $35.57 | 27.17% | 0.66% | 0.66% | (0.05%) | 80% | $2,345,237 |
Year Ended 12/31/2018 | $27.97 | 2.91% | 0.67% | 0.67% | 0.07% | 71% | $1,893,796 |
Year Ended 12/31/2017 | $27.18 | 32.58% | 0.72% | 0.72% | (0.03%) | 68% | $1,804,566 |
Year Ended 12/31/2016 | $20.50 | 3.27% | 0.78% | 0.78% | 0.42% | 130% | $1,063,778 |
Year Ended 12/31/2015 | $19.85 | 6.72% | 0.76% | 0.76% | 3.63% | 27% | $1,209,405 |
Class 2 | |||||||
Year Ended 12/31/2019 | $34.72 | 26.85% | 0.91% | 0.91% | (0.30%) | 80% | $19,150 |
Year Ended 12/31/2018 | $27.37 | 2.62% | 0.92% | 0.92% | (0.19%) | 71% | $13,254 |
Year Ended 12/31/2017 | $26.67 | 32.23% | 0.97% | 0.97% | (0.28%) | 68% | $9,269 |
Year Ended 12/31/2016 | $20.17 | 3.07% | 1.03% | 1.03% | 0.16% | 130% | $6,769 |
Year Ended 12/31/2015 | $19.57 | 6.42% | 1.01% | 1.01% | 3.08% | 27% | $7,758 |
Prospectus 2020 | 273 |
Prospectus 2020 | 275 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $20.69 | 0.52 | 4.98 | 5.50 |
Year Ended 12/31/2018 | $22.81 | 0.44 | (2.56) | (2.12) |
Year Ended 12/31/2017 | $19.62 | 0.37 | 2.82 | 3.19 |
Year Ended 12/31/2016 | $17.16 | 0.41 | 2.05 | 2.46 |
Year Ended 12/31/2015 | $18.69 | 0.42 | (1.95) | (1.53) |
Class 2 | ||||
Year Ended 12/31/2019 | $20.25 | 0.45 | 4.86 | 5.31 |
Year Ended 12/31/2018 | $22.38 | 0.38 | (2.51) | (2.13) |
Year Ended 12/31/2017 | $19.30 | 0.31 | 2.77 | 3.08 |
Year Ended 12/31/2016 | $16.92 | 0.36 | 2.02 | 2.38 |
Year Ended 12/31/2015 | $18.48 | 0.37 | (1.93) | (1.56) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
276 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $26.19 | 26.58% | 0.69% | 0.69% | 2.17% | 28% | $1,987,789 |
Year Ended 12/31/2018 | $20.69 | (9.30%) | 0.67% | 0.67% | 1.91% | 20% | $1,939,941 |
Year Ended 12/31/2017 | $22.81 | 16.26% | 0.70% | 0.70% | 1.75% | 32% | $2,481,560 |
Year Ended 12/31/2016 | $19.62 | 14.34% | 0.75% | 0.75% | 2.30% | 108% | $2,168,289 |
Year Ended 12/31/2015 | $17.16 | (8.19%) | 0.75% | 0.75% | 2.32% | 59% | $1,894,441 |
Class 2 | |||||||
Year Ended 12/31/2019 | $25.56 | 26.22% | 0.94% | 0.94% | 1.94% | 28% | $27,449 |
Year Ended 12/31/2018 | $20.25 | (9.52%) | 0.92% | 0.92% | 1.70% | 20% | $20,084 |
Year Ended 12/31/2017 | $22.38 | 15.96% | 0.94% | 0.94% | 1.52% | 32% | $17,050 |
Year Ended 12/31/2016 | $19.30 | 14.07% | 1.00% | 1.00% | 2.05% | 108% | $10,555 |
Year Ended 12/31/2015 | $16.92 | (8.44%) | 1.00% | 1.00% | 2.06% | 59% | $8,459 |
Prospectus 2020 | 277 |
Prospectus 2020 | 279 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.38 | 0.29 | 0.64 | 0.93 | (0.30) | — | (0.30) |
Year Ended 12/31/2018 | $10.62 | 0.27 | (0.27) | 0.00 | (0.22) | (0.02) | (0.24) |
Year Ended 12/31/2017 | $10.48 | 0.21 | 0.14 | 0.35 | (0.17) | (0.04) | (0.21) |
Year Ended 12/31/2016 | $10.40 | 0.17 | 0.08 | 0.25 | (0.13) | (0.04) | (0.17) |
Year Ended 12/31/2015 | $10.47 | 0.14 | (0.12) | 0.02 | (0.09) | (0.00) (c) | (0.09) |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.35 | 0.25 | 0.63 | 0.88 | (0.27) | — | (0.27) |
Year Ended 12/31/2018 | $10.58 | 0.25 | (0.26) | (0.01) | (0.20) | (0.02) | (0.22) |
Year Ended 12/31/2017 | $10.44 | 0.18 | 0.15 | 0.33 | (0.15) | (0.04) | (0.19) |
Year Ended 12/31/2016 | $10.36 | 0.15 | 0.08 | 0.23 | (0.11) | (0.04) | (0.15) |
Year Ended 12/31/2015 | $10.43 | 0.12 | (0.13) | (0.01) | (0.06) | (0.00) (c) | (0.06) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
280 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $11.01 | 9.01% | 0.49% | 0.49% | 2.65% | 209% | $2,808,764 |
Year Ended 12/31/2018 | $10.38 | 0.06% | 0.49% | 0.49% | 2.61% | 178% | $2,714,909 |
Year Ended 12/31/2017 | $10.62 | 3.40% | 0.52% | 0.52% | 1.97% | 281% | $2,979,922 |
Year Ended 12/31/2016 | $10.48 | 2.41% | 0.56% | 0.55% | 1.61% | 276% | $3,079,179 |
Year Ended 12/31/2015 | $10.40 | 0.19% | 0.58% | 0.56% | 1.35% | 351% | $3,154,641 |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.96 | 8.58% | 0.74% | 0.74% | 2.37% | 209% | $12,125 |
Year Ended 12/31/2018 | $10.35 | (0.10%) | 0.74% | 0.74% | 2.38% | 178% | $7,961 |
Year Ended 12/31/2017 | $10.58 | 3.15% | 0.77% | 0.77% | 1.73% | 281% | $7,071 |
Year Ended 12/31/2016 | $10.44 | 2.17% | 0.81% | 0.80% | 1.38% | 276% | $6,052 |
Year Ended 12/31/2015 | $10.36 | (0.06%) | 0.83% | 0.81% | 1.10% | 351% | $4,137 |
Prospectus 2020 | 281 |
Prospectus 2020 | 283 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.03 | 0.24 | 0.12 | 0.36 | (0.11) | — | (0.11) |
Year Ended 12/31/2018 | $10.06 | 0.20 | (0.10) | 0.10 | (0.13) | — | (0.13) |
Year Ended 12/31/2017 | $10.08 | 0.12 | (0.04) | 0.08 | (0.10) | (0.00) (c) | (0.10) |
Year Ended 12/31/2016 | $10.11 | 0.09 | 0.02 | 0.11 | (0.10) | (0.04) | (0.14) |
Year Ended 12/31/2015 | $10.18 | 0.07 | (0.04) | 0.03 | (0.10) | — | (0.10) |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.99 | 0.21 | 0.12 | 0.33 | (0.08) | — | (0.08) |
Year Ended 12/31/2018 | $10.01 | 0.17 | (0.09) | 0.08 | (0.10) | — | (0.10) |
Year Ended 12/31/2017 | $10.04 | 0.09 | (0.05) | 0.04 | (0.07) | (0.00) (c) | (0.07) |
Year Ended 12/31/2016 | $10.07 | 0.06 | 0.02 | 0.08 | (0.07) | (0.04) | (0.11) |
Year Ended 12/31/2015 | $10.14 | 0.04 | (0.03) | 0.01 | (0.08) | — | (0.08) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Rounds to zero. |
284 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.28 | 3.57% | 0.43% | 0.43% | 2.31% | 632% | $1,504,778 |
Year Ended 12/31/2018 | $10.03 | 0.96% | 0.44% | 0.44% | 1.97% | 414% | $1,944,337 |
Year Ended 12/31/2017 | $10.06 | 0.80% | 0.47% | 0.47% | 1.15% | 290% | $956,370 |
Year Ended 12/31/2016 | $10.08 | 1.03% | 0.56% | 0.55% | 0.86% | 343% | $1,056,643 |
Year Ended 12/31/2015 | $10.11 | 0.32% | 0.60% | 0.60% | 0.64% | 375% | $1,197,705 |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.24 | 3.33% | 0.68% | 0.68% | 2.04% | 632% | $29,635 |
Year Ended 12/31/2018 | $9.99 | 0.81% | 0.69% | 0.69% | 1.68% | 414% | $25,361 |
Year Ended 12/31/2017 | $10.01 | 0.45% | 0.72% | 0.72% | 0.91% | 290% | $22,203 |
Year Ended 12/31/2016 | $10.04 | 0.78% | 0.80% | 0.80% | 0.63% | 343% | $22,083 |
Year Ended 12/31/2015 | $10.07 | 0.07% | 0.86% | 0.85% | 0.40% | 375% | $13,574 |
Prospectus 2020 | 285 |
Prospectus 2020 | 287 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $22.64 | 0.07 | 9.47 | 9.54 |
Year Ended 12/31/2018 | $23.43 | 0.01 | (0.80) | (0.79) |
Year Ended 12/31/2017 | $19.06 | 0.01 | 4.36 | 4.37 |
Year Ended 12/31/2016 | $18.38 | (0.02) | 0.70 | 0.68 |
Year Ended 12/31/2015 | $18.90 | (0.04) | (0.48) (c) | (0.52) |
Class 2 | ||||
Year Ended 12/31/2019 | $22.13 | 0.01 | 9.24 | 9.25 |
Year Ended 12/31/2018 | $22.96 | (0.05) | (0.78) | (0.83) |
Year Ended 12/31/2017 | $18.72 | (0.04) | 4.28 | 4.24 |
Year Ended 12/31/2016 | $18.10 | (0.07) | 0.69 | 0.62 |
Year Ended 12/31/2015 | $18.66 | (0.08) | (0.48) (c) | (0.56) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Calculation of the net gain (loss) per share (both realized and unrealized) does not correlate to the aggregate realized and unrealized gain (loss) presented in the Statement of Operations due to the timing of subscriptions and redemptions of Fund shares in relation to fluctuations in the market value of the portfolio. |
288 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $32.18 | 42.14% | 0.83% | 0.83% | 0.25% | 70% | $555,819 |
Year Ended 12/31/2018 | $22.64 | (3.37%) | 0.84% | 0.84% | 0.05% | 72% | $491,881 |
Year Ended 12/31/2017 | $23.43 | 22.93% | 0.87% | 0.87% | 0.04% | 121% | $515,408 |
Year Ended 12/31/2016 | $19.06 | 3.70% | 0.90% | 0.88% | (0.11%) | 36% | $411,066 |
Year Ended 12/31/2015 | $18.38 | (2.75%) | 0.89% | 0.88% | (0.20%) | 34% | $217,012 |
Class 2 | |||||||
Year Ended 12/31/2019 | $31.38 | 41.80% | 1.08% | 1.08% | 0.02% | 70% | $26,048 |
Year Ended 12/31/2018 | $22.13 | (3.61%) | 1.09% | 1.09% | (0.20%) | 72% | $18,181 |
Year Ended 12/31/2017 | $22.96 | 22.65% | 1.12% | 1.12% | (0.21%) | 121% | $19,303 |
Year Ended 12/31/2016 | $18.72 | 3.43% | 1.15% | 1.13% | (0.38%) | 36% | $13,635 |
Year Ended 12/31/2015 | $18.10 | (3.00%) | 1.15% | 1.13% | (0.42%) | 34% | $12,750 |
Prospectus 2020 | 289 |
Prospectus 2020 | 291 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $10.52 | 0.29 | 0.61 | 0.90 | (0.27) | — | (0.27) |
Year Ended 12/31/2018 | $10.94 | 0.29 | (0.31) | (0.02) | (0.27) | (0.13) | (0.40) |
Year Ended 12/31/2017 | $10.82 | 0.26 | 0.12 | 0.38 | (0.25) | (0.01) | (0.26) |
Year Ended 12/31/2016 | $10.80 | 0.25 | 0.02 | 0.27 | (0.23) | (0.02) | (0.25) |
Year Ended 12/31/2015 | $10.94 | 0.24 | (0.14) | 0.10 | (0.21) | (0.03) | (0.24) |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.47 | 0.26 | 0.61 | 0.87 | (0.24) | — | (0.24) |
Year Ended 12/31/2018 | $10.89 | 0.26 | (0.30) | (0.04) | (0.25) | (0.13) | (0.38) |
Year Ended 12/31/2017 | $10.77 | 0.23 | 0.13 | 0.36 | (0.23) | (0.01) | (0.24) |
Year Ended 12/31/2016 | $10.75 | 0.22 | 0.03 | 0.25 | (0.21) | (0.02) | (0.23) |
Year Ended 12/31/2015 | $10.90 | 0.21 | (0.15) | 0.06 | (0.18) | (0.03) | (0.21) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
292 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $11.15 | 8.61% | 0.48% | 0.48% | 2.69% | 321% | $3,759,623 |
Year Ended 12/31/2018 | $10.52 | (0.09%) | 0.49% | 0.49% | 2.75% | 309% | $3,535,290 |
Year Ended 12/31/2017 | $10.94 | 3.58% | 0.52% | 0.52% | 2.39% | 240% | $3,284,310 |
Year Ended 12/31/2016 | $10.82 | 2.48% | 0.56% | 0.56% | 2.27% | 17% | $3,343,966 |
Year Ended 12/31/2015 | $10.80 | 0.88% | 0.57% | 0.56% | 2.18% | 20% | $3,363,421 |
Class 2 | |||||||
Year Ended 12/31/2019 | $11.10 | 8.39% | 0.73% | 0.73% | 2.43% | 321% | $11,721 |
Year Ended 12/31/2018 | $10.47 | (0.35%) | 0.74% | 0.74% | 2.50% | 309% | $9,303 |
Year Ended 12/31/2017 | $10.89 | 3.34% | 0.77% | 0.77% | 2.15% | 240% | $10,669 |
Year Ended 12/31/2016 | $10.77 | 2.23% | 0.82% | 0.81% | 2.03% | 17% | $10,146 |
Year Ended 12/31/2015 | $10.75 | 0.54% | 0.82% | 0.81% | 1.94% | 20% | $6,999 |
Prospectus 2020 | 293 |
Prospectus 2020 | 295 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.70 | 0.29 | 1.50 | 1.79 | (0.30) | (0.16) | (0.46) |
Year Ended 12/31/2018 | $11.92 | 0.25 | (2.18) | (1.93) | (0.26) | (0.03) | (0.29) |
Year Ended 12/31/2017 | $9.91 | 0.20 | 2.02 | 2.22 | (0.21) | — | (0.21) |
Year Ended 12/31/2016 | $10.48 | 0.20 | (0.54) | (0.34) | (0.23) | — | (0.23) |
Year Ended 12/31/2015 | $10.99 | 0.15 | (0.16) | (0.01) | (0.16) | (0.34) | (0.50) |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.64 | 0.25 | 1.50 | 1.75 | (0.27) | (0.16) | (0.43) |
Year Ended 12/31/2018 | $11.84 | 0.22 | (2.16) | (1.94) | (0.23) | (0.03) | (0.26) |
Year Ended 12/31/2017 | $9.86 | 0.17 | 2.00 | 2.17 | (0.19) | — | (0.19) |
Year Ended 12/31/2016 | $10.43 | 0.18 | (0.54) | (0.36) | (0.21) | — | (0.21) |
Year Ended 12/31/2015 | $10.94 | 0.13 | (0.16) | (0.03) | (0.14) | (0.34) | (0.48) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
296 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $11.03 | 18.76% | 0.79% | 0.79% | 2.74% | 94% | $2,893,855 |
Year Ended 12/31/2018 | $9.70 | (16.53%) | 0.83% | 0.83% | 2.23% | 105% | $2,766,782 |
Year Ended 12/31/2017 | $11.92 | 22.56% | 0.92% | 0.92% | 1.79% | 68% | $2,606,365 |
Year Ended 12/31/2016 | $9.91 | (3.24%) | 0.97% | 0.96% | 2.04% | 50% | $2,317,135 |
Year Ended 12/31/2015 | $10.48 | (0.41%) | 0.97% | 0.97% | 1.37% | 52% | $2,317,553 |
Class 2 | |||||||
Year Ended 12/31/2019 | $10.96 | 18.41% | 1.04% | 1.04% | 2.45% | 94% | $8,279 |
Year Ended 12/31/2018 | $9.64 | (16.69%) | 1.08% | 1.08% | 1.99% | 105% | $6,925 |
Year Ended 12/31/2017 | $11.84 | 22.14% | 1.17% | 1.17% | 1.50% | 68% | $8,554 |
Year Ended 12/31/2016 | $9.86 | (3.44%) | 1.22% | 1.21% | 1.85% | 50% | $6,722 |
Year Ended 12/31/2015 | $10.43 | (0.60%) | 1.22% | 1.22% | 1.13% | 52% | $7,749 |
Prospectus 2020 | 297 |
Prospectus 2020 | 299 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.46 | 0.10 | 2.38 | 2.48 | (0.12) | (0.36) | (0.48) |
Year Ended 12/31/2018 | $12.29 | 0.11 | (2.35) | (2.24) | (0.12) | (0.47) | (0.59) |
Year Ended 12/31/2017 | $10.70 | 0.11 | 2.65 | 2.76 | (0.09) | (1.08) | (1.17) |
Year Ended 12/31/2016 | $11.36 | 0.15 | (0.54) | (0.39) | (0.15) | (0.12) | (0.27) |
Year Ended 12/31/2015 | $12.46 | 0.17 | (0.41) | (0.24) | (0.17) | (0.69) | (0.86) |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.42 | 0.07 | 2.37 | 2.44 | (0.10) | (0.36) | (0.46) |
Year Ended 12/31/2018 | $12.24 | 0.07 | (2.32) | (2.25) | (0.10) | (0.47) | (0.57) |
Year Ended 12/31/2017 | $10.66 | 0.08 | 2.64 | 2.72 | (0.06) | (1.08) | (1.14) |
Year Ended 12/31/2016 | $11.32 | 0.12 | (0.53) | (0.41) | (0.13) | (0.12) | (0.25) |
Year Ended 12/31/2015 | $12.42 | 0.13 | (0.40) | (0.27) | (0.14) | (0.69) | (0.83) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
300 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $11.46 | 26.70% | 0.93% | 0.92% | 0.92% | 113% | $1,057,916 |
Year Ended 12/31/2018 | $9.46 | (18.95%) | 0.91% | 0.91% | 0.92% | 19% | $793,614 |
Year Ended 12/31/2017 | $12.29 | 26.87% | 0.95% | 0.95% | 0.93% | 22% | $1,682,196 |
Year Ended 12/31/2016 | $10.70 | (3.47%) | 0.96% | 0.96% | 1.37% | 94% | $2,270,612 |
Year Ended 12/31/2015 | $11.36 | (2.27%) | 0.97% | 0.97% | 1.38% | 19% | $2,299,811 |
Class 2 | |||||||
Year Ended 12/31/2019 | $11.40 | 26.36% | 1.18% | 1.17% | 0.67% | 113% | $35,306 |
Year Ended 12/31/2018 | $9.42 | (19.10%) | 1.17% | 1.17% | 0.64% | 19% | $29,694 |
Year Ended 12/31/2017 | $12.24 | 26.56% | 1.20% | 1.20% | 0.67% | 22% | $33,356 |
Year Ended 12/31/2016 | $10.66 | (3.66%) | 1.21% | 1.21% | 1.11% | 94% | $21,570 |
Year Ended 12/31/2015 | $11.32 | (2.54%) | 1.22% | 1.22% | 1.09% | 19% | $20,973 |
Prospectus 2020 | 301 |
Prospectus 2020 | 303 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.17 | 0.30 | 0.91 | 1.21 | (0.38) | (0.29) | (0.67) |
Year Ended 12/31/2018 | $11.47 | 0.29 | (2.23) | (1.94) | (0.31) | (0.05) | (0.36) |
Year Ended 12/31/2017 | $9.34 | 0.26 | 2.09 | 2.35 | (0.22) | — | (0.22) |
Year Ended 12/31/2016 | $8.91 | 0.25 | 0.46 | 0.71 | (0.24) | (0.04) | (0.28) |
Year Ended 12/31/2015 | $10.03 | 0.22 | (0.92) | (0.70) | (0.21) | (0.21) | (0.42) |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.15 | 0.28 | 0.90 | 1.18 | (0.35) | (0.29) | (0.64) |
Year Ended 12/31/2018 | $11.44 | 0.26 | (2.22) | (1.96) | (0.28) | (0.05) | (0.33) |
Year Ended 12/31/2017 | $9.33 | 0.23 | 2.08 | 2.31 | (0.20) | — | (0.20) |
Year Ended 12/31/2016 | $8.90 | 0.22 | 0.47 | 0.69 | (0.22) | (0.04) | (0.26) |
Year Ended 12/31/2015 | $10.01 | 0.20 | (0.92) | (0.72) | (0.18) | (0.21) | (0.39) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interfund lending expense which is less than 0.01%. |
(d) | Ratios include line of credit interest expense which is less than 0.01%. |
304 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.71 | 13.53% | 0.88% (c) | 0.88% (c) | 3.17% | 22% | $1,028,139 |
Year Ended 12/31/2018 | $9.17 | (17.30%) | 0.83% | 0.83% | 2.70% | 16% | $821,718 |
Year Ended 12/31/2017 | $11.47 | 25.44% | 0.86% | 0.86% | 2.48% | 9% | $1,759,557 |
Year Ended 12/31/2016 | $9.34 | 8.33% | 0.91% (d) | 0.91% (d) | 2.89% | 17% | $2,000,961 |
Year Ended 12/31/2015 | $8.91 | (7.40%) | 0.98% | 0.98% | 2.25% | 12% | $1,987,543 |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.69 | 13.20% | 1.13% (c) | 1.13% (c) | 2.93% | 22% | $23,667 |
Year Ended 12/31/2018 | $9.15 | (17.48%) | 1.09% | 1.09% | 2.41% | 16% | $19,537 |
Year Ended 12/31/2017 | $11.44 | 25.02% | 1.11% | 1.11% | 2.18% | 9% | $20,666 |
Year Ended 12/31/2016 | $9.33 | 8.08% | 1.16% (d) | 1.16% (d) | 2.52% | 17% | $12,345 |
Year Ended 12/31/2015 | $8.90 | (7.56%) | 1.23% | 1.23% | 2.06% | 12% | $10,494 |
Prospectus 2020 | 305 |
Prospectus 2020 | 307 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $20.93 | (0.09) | 4.54 | 4.45 |
Year Ended 12/31/2018 | $21.95 | (0.11) | (0.91) | (1.02) |
Year Ended 12/31/2017 | $18.48 | (0.08) | 3.55 | 3.47 |
Year Ended 12/31/2016 | $17.33 | (0.04) | 1.19 | 1.15 |
Year Ended 12/31/2015 | $18.25 | (0.04) | (0.88) | (0.92) |
Class 2 | ||||
Year Ended 12/31/2019 | $20.48 | (0.14) | 4.43 | 4.29 |
Year Ended 12/31/2018 | $21.53 | (0.17) | (0.88) | (1.05) |
Year Ended 12/31/2017 | $18.17 | (0.13) | 3.49 | 3.36 |
Year Ended 12/31/2016 | $17.08 | (0.08) | 1.17 | 1.09 |
Year Ended 12/31/2015 | $18.04 | (0.08) | (0.88) | (0.96) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
308 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $25.38 | 21.26% | 0.88% | 0.87% | (0.38%) | 90% | $574,507 |
Year Ended 12/31/2018 | $20.93 | (4.65%) | 0.87% | 0.86% | (0.46%) | 113% | $579,389 |
Year Ended 12/31/2017 | $21.95 | 18.78% | 0.91% | 0.91% | (0.42%) | 114% | $644,746 |
Year Ended 12/31/2016 | $18.48 | 6.64% | 0.98% | 0.94% | (0.25%) | 90% | $611,339 |
Year Ended 12/31/2015 | $17.33 | (5.04%) | 1.02% | 0.96% | (0.20%) | 63% | $609,772 |
Class 2 | |||||||
Year Ended 12/31/2019 | $24.77 | 20.95% | 1.13% | 1.12% | (0.62%) | 90% | $11,277 |
Year Ended 12/31/2018 | $20.48 | (4.88%) | 1.12% | 1.11% | (0.70%) | 113% | $8,375 |
Year Ended 12/31/2017 | $21.53 | 18.49% | 1.16% | 1.16% | (0.67%) | 114% | $7,101 |
Year Ended 12/31/2016 | $18.17 | 6.38% | 1.23% | 1.19% | (0.50%) | 90% | $5,031 |
Year Ended 12/31/2015 | $17.08 | (5.32%) | 1.27% | 1.21% | (0.46%) | 63% | $4,734 |
Prospectus 2020 | 309 |
SUMMARIES OF THE FUNDS
Investment Objective, Fees and Expenses of the Fund, Principal Investment Strategies, Principal Risks, Performance Information, Fund Management, Purchase and Sale of Fund Shares, Tax Information, Payments to Broker-Dealers and Other Financial Intermediaries |
|
|
3 |
|
13 |
|
23 |
|
33 |
|
43 |
|
53 |
|
53 |
|
53 |
|
55 |
|
64 |
|
69 |
|
71 |
|
72 |
|
73 |
|
73 |
|
74 |
|
75 |
|
76 |
|
81 |
|
81 |
|
81 |
|
83 |
|
A-1 |
|
B-1 |
2 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $70 | $221 | $384 | $859 |
Class 2 (whether or not shares are redeemed) | $96 | $300 | $520 | $1,155 |
Class 4 (whether or not shares are redeemed) | $96 | $300 | $520 | $1,155 |
Prospectus 2020 | 3 |
Asset Class Exposures | ||||
(Target Allocation Range – Under Normal Circumstances)* | ||||
Equity |
Fixed
Income |
Cash/Cash
Equivalents |
Alternative
Strategies |
|
Conservative Portfolio | 10–25%* | 60-80%* | 0-10%* | 0–10%* |
* | As a percent of Fund net assets. Ranges include the net notional amounts of a Fund’s direct investments in derivative instruments. Market appreciation or depreciation may cause a Fund to be temporarily outside the ranges identified in the table. Columbia Management Investment Advisers, LLC (Columbia Management or the Investment Manager) may modify the target allocation ranges only with the approval of a Fund’s Board of Trustees (the Board). |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
10 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 4.89% |
Worst
|
3rd Quarter 2011 | -3.13% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 11.05% | 3.64% | 4.35% |
Class 2 | 05/07/2010 | 10.75% | 3.58% | 4.32% |
Class 4 | 05/07/2010 | 10.75% | 3.58% | 4.32% |
Blended Benchmark (consisting of 80% Bloomberg Barclays U.S. Aggregate Bond Index, 14% Russell 3000 Index and 6% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 12.57% | 4.46% | 5.29% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 11.24% | 13.83% | |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 5.67% | 6.98% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Lead Portfolio Manager | 2015 | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 11 |
12 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $73 | $227 | $395 | $883 |
Class 2 (whether or not shares are redeemed) | $98 | $306 | $531 | $1,178 |
Class 4 (whether or not shares are redeemed) | $98 | $306 | $531 | $1,178 |
Prospectus 2020 | 13 |
Asset Class Exposures | ||||
(Target Allocation Range – Under Normal Circumstances)* | ||||
Equity |
Fixed
Income |
Cash/Cash
Equivalents |
Alternative
Strategies |
|
Moderately Conservative Portfolio | 25-40%* | 50-65%* | 0-10%* | 0–10%* |
* | As a percent of Fund net assets. Ranges include the net notional amounts of a Fund’s direct investments in derivative instruments. Market appreciation or depreciation may cause a Fund to be temporarily outside the ranges identified in the table. Columbia Management Investment Advisers, LLC (Columbia Management or the Investment Manager) may modify the target allocation ranges only with the approval of a Fund’s Board of Trustees (the Board). |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
16 | Prospectus 2020 |
Prospectus 2020 | 17 |
18 | Prospectus 2020 |
Prospectus 2020 | 19 |
20 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 6.42% |
Worst
|
3rd Quarter 2011 | -5.82% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 13.79% | 4.48% | 5.45% |
Class 2 | 05/07/2010 | 13.51% | 4.43% | 5.42% |
Class 4 | 05/07/2010 | 13.49% | 4.42% | 5.44% |
Blended Benchmark (consisting of 65% Bloomberg Barclays U.S. Aggregate Bond Index, 24% Russell 3000 Index and 11% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 15.44% | 5.46% | 6.54% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 11.24% | 13.83% | |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 5.67% | 6.98% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Lead Portfolio Manager | 2015 | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $76 | $237 | $411 | $918 |
Class 2 (whether or not shares are redeemed) | $101 | $315 | $547 | $1,213 |
Class 4 (whether or not shares are redeemed) | $101 | $315 | $547 | $1,213 |
Prospectus 2020 | 23 |
Asset Class Exposures | ||||
(Target Allocation Range – Under Normal Circumstances)* | ||||
Equity |
Fixed
Income |
Cash/Cash
Equivalents |
Alternative
Strategies |
|
Moderate Portfolio | 40-55%* | 40-55%* | 0-5%* | 0–10%* |
* | As a percent of Fund net assets. Ranges include the net notional amounts of a Fund’s direct investments in derivative instruments. Market appreciation or depreciation may cause a Fund to be temporarily outside the ranges identified in the table. Columbia Management Investment Advisers, LLC (Columbia Management or the Investment Manager) may modify the target allocation ranges only with the approval of a Fund’s Board of Trustees (the Board). |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
28 | Prospectus 2020 |
Prospectus 2020 | 29 |
30 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.91% |
Worst
|
3rd Quarter 2011 | -8.81% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 16.40% | 5.30% | 6.62% |
Class 2 | 05/07/2010 | 16.13% | 5.26% | 6.59% |
Class 4 | 05/07/2010 | 16.18% | 5.26% | 6.61% |
Blended Benchmark (consisting of 50% Bloomberg Barclays U.S. Aggregate Bond Index, 35% Russell 3000 Index and 15% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 18.41% | 6.49% | 7.83% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 11.24% | 13.83% | |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 5.67% | 6.98% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Lead Portfolio Manager | 2015 | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 31 |
32 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $80 | $249 | $433 | $966 |
Class 2 (whether or not shares are redeemed) | $105 | $328 | $569 | $1,259 |
Class 4 (whether or not shares are redeemed) | $105 | $328 | $569 | $1,259 |
Prospectus 2020 | 33 |
Asset Class Exposures | ||||
(Target Allocation Range – Under Normal Circumstances)* | ||||
Equity |
Fixed
Income |
Cash/Cash
Equivalents |
Alternative
Strategies |
|
Moderately Aggressive Portfolio | 55-70%* | 25-40%* | 0-5%* | 0–10%* |
* | As a percent of Fund net assets. Ranges include the net notional amounts of a Fund’s direct investments in derivative instruments. Market appreciation or depreciation may cause a Fund to be temporarily outside the ranges identified in the table. Columbia Management Investment Advisers, LLC (Columbia Management or the Investment Manager) may modify the target allocation ranges only with the approval of a Fund’s Board of Trustees (the Board). |
34 | Prospectus 2020 |
Prospectus 2020 | 35 |
36 | Prospectus 2020 |
Prospectus 2020 | 37 |
38 | Prospectus 2020 |
Prospectus 2020 | 39 |
40 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 9.33% |
Worst
|
3rd Quarter 2011 | -11.78% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 18.96% | 6.06% | 7.61% |
Class 2 | 05/07/2010 | 18.71% | 6.02% | 7.59% |
Class 4 | 05/07/2010 | 18.75% | 6.01% | 7.61% |
Blended Benchmark (consisting of 46% Russell 3000 Index, 35% Bloomberg Barclays U.S. Aggregate Bond Index and 19% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 21.40% | 7.49% | 9.09% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 11.24% | 13.83% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% | |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 5.67% | 6.98% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Lead Portfolio Manager | 2015 | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 41 |
42 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $83 | $259 | $450 | $1,002 |
Class 2 (whether or not shares are redeemed) | $108 | $337 | $585 | $1,294 |
Class 4 (whether or not shares are redeemed) | $108 | $337 | $585 | $1,294 |
Prospectus 2020 | 43 |
Asset Class Exposures | ||||
(Target Allocation Range – Under Normal Circumstances)* | ||||
Equity |
Fixed
Income |
Cash/Cash
Equivalents |
Alternative
Strategies |
|
Aggressive Portfolio | 70-85%* | 10-25%* | 0-5%* | 0–10%* |
* | As a percent of Fund net assets. Ranges include the net notional amounts of a Fund’s direct investments in derivative instruments. Market appreciation or depreciation may cause a Fund to be temporarily outside the ranges identified in the table. Columbia Management Investment Advisers, LLC (Columbia Management or the Investment Manager) may modify the target allocation ranges only with the approval of a Fund’s Board of Trustees (the Board). |
44 | Prospectus 2020 |
Prospectus 2020 | 45 |
46 | Prospectus 2020 |
Prospectus 2020 | 47 |
48 | Prospectus 2020 |
Prospectus 2020 | 49 |
50 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 10.88% |
Worst
|
3rd Quarter 2011 | -14.50% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 21.84% | 6.84% | 8.66% |
Class 2 | 05/07/2010 | 21.59% | 6.80% | 8.63% |
Class 4 | 05/07/2010 | 21.68% | 6.81% | 8.66% |
Blended Benchmark (consisting of 56% Russell 3000 Index, 24% MSCI EAFE Index (Net) and 20% Bloomberg Barclays U.S. Aggregate Bond Index) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 24.32% | 8.40% | 10.25% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 11.24% | 13.83% | |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 5.67% | 6.98% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 3.53% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Lead Portfolio Manager | 2015 | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 51 |
52 | Prospectus 2020 |
Prospectus 2020 | 53 |
Asset Class Exposures | ||||
(Target Allocation Range – Under Normal Circumstances)* | ||||
Equity |
Fixed
Income |
Cash/Cash
Equivalents |
Alternative
Strategies |
|
Conservative Portfolio | 10-25%* | 60-80%* | 0-10%* | 0-10%* |
Moderately Conservative Portfolio | 25-40%* | 50-65%* | 0-10%* | 0-10%* |
Moderate Portfolio | 40-55%* | 40-55%* | 0-5%* | 0-10%* |
Moderately Aggressive Portfolio | 55-70%* | 25-40%* | 0-5%* | 0-10%* |
Aggressive Portfolio | 70-85%* | 10-25%* | 0-5%* | 0-10%* |
* | As a percentage of Fund net assets. Ranges include the net notional amounts of a Fund’s direct investments in derivative instruments. Market appreciation or depreciation may cause the Fund to be temporarily outside the range identified in the table. The Investment Manager may modify the target allocation ranges only upon approval of the Fund’s Board of Trustees (the Board). |
54 | Prospectus 2020 |
Prospectus 2020 | 55 |
56 | Prospectus 2020 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
Prospectus 2020 | 57 |
■ | A bond (or debt instrument) future is a derivative that is an agreement for the contract holder to buy or sell a bond or other debt instrument, a basket of bonds or other debt instrument, or the bonds or other debt instruments in an index on a specified date at a predetermined price. The buyer (long position) of a bond future is obliged to buy the underlying reference at the agreed price on expiry of the future. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
58 | Prospectus 2020 |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including LIBOR, swap rates, treasury rates and foreign interest rates. |
■ | Total return swaps are derivative swap transactions in which one party agrees to pay the other party an amount equal to the total return of a defined underlying reference during a specified period of time. In return, the other party would make periodic payments based on a fixed or variable interest rate or on the total return of a different underlying reference. |
Prospectus 2020 | 59 |
60 | Prospectus 2020 |
Prospectus 2020 | 61 |
62 | Prospectus 2020 |
Prospectus 2020 | 63 |
64 | Prospectus 2020 |
Prospectus 2020 | 65 |
66 | Prospectus 2020 |
Prospectus 2020 | 67 |
68 | Prospectus 2020 |
Variable Portfolio – Moderately Conservative Portfolio | |
Class 1 | 0.22% |
Class 2 | 0.47% |
Class 4 | 0.47% |
Prospectus 2020 | 69 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Lead Portfolio Manager | 2015 | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
70 | Prospectus 2020 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
Prospectus 2020 | 71 |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
72 | Prospectus 2020 |
Class 1 Shares | Class 2 Shares | Class 4 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and in variable life insurance policies (collectively, Contracts) or other eligible investors authorized by the Distributor. | Class 2 shares are offered to Accounts funding variable annuity contracts and variable life insurance policies issued by affiliated life insurance companies. | Class 4 shares are offered to participants in the Portfolio Navigator Program, and to owners of other series of annuity contracts or life insurance policies issued by RiverSource Life Insurance Company or RiverSource Life Insurance Co. of New York, as described in the prospectus for that annuity contract or life insurance policy. |
Investment Limits | none | none | none |
Conversion Features | none | none | none |
Front-End Sales Charges | none | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% | 0.25% |
Prospectus 2020 | 73 |
74 | Prospectus 2020 |
Prospectus 2020 | 75 |
76 | Prospectus 2020 |
Prospectus 2020 | 77 |
78 | Prospectus 2020 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
Prospectus 2020 | 79 |
80 | Prospectus 2020 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. |
Prospectus 2020 | 81 |
82 | Prospectus 2020 |
Prospectus 2020 | 83 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $13.95 | 0.13 | 0.90 | 1.03 |
Class 2 | ||||
Year Ended 12/31/2019 | $13.49 | 0.27 | 1.18 | 1.45 |
Year Ended 12/31/2018 | $13.90 | 0.22 | (0.63) | (0.41) |
Year Ended 12/31/2017 | $12.94 | 0.22 | 0.74 | 0.96 |
Year Ended 12/31/2016 | $12.51 | 0.17 | 0.26 | 0.43 |
Year Ended 12/31/2015 | $12.53 | 0.17 | (0.19) | (0.02) |
Class 4 | ||||
Year Ended 12/31/2019 | $13.49 | 0.28 | 1.17 | 1.45 |
Year Ended 12/31/2018 | $13.89 | 0.22 | (0.62) | (0.40) |
Year Ended 12/31/2017 | $12.94 | 0.21 | 0.74 | 0.95 |
Year Ended 12/31/2016 | $12.51 | 0.17 | 0.26 | 0.43 |
Year Ended 12/31/2015 | $12.53 | 0.17 | (0.19) | (0.02) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
84 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $14.98 | 7.38% | 0.13% (d) | 0.13% (d) | 1.10% (d) | 18% | $173 |
Class 2 | |||||||
Year Ended 12/31/2019 | $14.94 | 10.75% | 0.38% | 0.38% | 1.90% | 18% | $520,608 |
Year Ended 12/31/2018 | $13.49 | (2.95%) | 0.37% | 0.37% | 1.61% | 18% | $450,440 |
Year Ended 12/31/2017 | $13.90 | 7.42% | 0.33% | 0.33% | 1.60% | 6% | $541,013 |
Year Ended 12/31/2016 | $12.94 | 3.44% | 0.30% | 0.30% | 1.34% | 14% | $593,909 |
Year Ended 12/31/2015 | $12.51 | (0.16%) | 0.28% | 0.28% | 1.35% | 27% | $557,777 |
Class 4 | |||||||
Year Ended 12/31/2019 | $14.94 | 10.75% | 0.38% | 0.38% | 1.94% | 18% | $562,599 |
Year Ended 12/31/2018 | $13.49 | (2.88%) | 0.37% | 0.37% | 1.60% | 18% | $570,600 |
Year Ended 12/31/2017 | $13.89 | 7.34% | 0.33% | 0.33% | 1.59% | 6% | $725,015 |
Year Ended 12/31/2016 | $12.94 | 3.44% | 0.30% | 0.30% | 1.35% | 14% | $873,507 |
Year Ended 12/31/2015 | $12.51 | (0.16%) | 0.28% | 0.28% | 1.35% | 27% | $890,458 |
Prospectus 2020 | 85 |
Prospectus 2020 | 87 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $15.35 | 0.26 | 1.05 | 1.31 |
Class 2 | ||||
Year Ended 12/31/2019 | $14.65 | 0.24 | 1.74 | 1.98 |
Year Ended 12/31/2018 | $15.28 | 0.20 | (0.83) | (0.63) |
Year Ended 12/31/2017 | $13.89 | 0.19 | 1.20 | 1.39 |
Year Ended 12/31/2016 | $13.36 | 0.16 | 0.37 | 0.53 |
Year Ended 12/31/2015 | $13.39 | 0.17 | (0.20) | (0.03) |
Class 4 | ||||
Year Ended 12/31/2019 | $14.68 | 0.25 | 1.73 | 1.98 |
Year Ended 12/31/2018 | $15.30 | 0.20 | (0.82) | (0.62) |
Year Ended 12/31/2017 | $13.92 | 0.19 | 1.19 | 1.38 |
Year Ended 12/31/2016 | $13.38 | 0.16 | 0.38 | 0.54 |
Year Ended 12/31/2015 | $13.42 | 0.17 | (0.21) | (0.04) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
88 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $16.66 | 8.53% | 0.12% (d) | 0.11% (d) | 1.91% (d) | 12% | $156 |
Class 2 | |||||||
Year Ended 12/31/2019 | $16.63 | 13.51% | 0.37% | 0.36% | 1.54% | 12% | $1,463,901 |
Year Ended 12/31/2018 | $14.65 | (4.12%) | 0.36% | 0.36% | 1.31% | 10% | $1,311,637 |
Year Ended 12/31/2017 | $15.28 | 10.01% | 0.33% | 0.33% | 1.30% | 4% | $1,539,179 |
Year Ended 12/31/2016 | $13.89 | 3.97% | 0.30% | 0.30% | 1.18% | 8% | $1,567,642 |
Year Ended 12/31/2015 | $13.36 | (0.22%) | 0.28% | 0.28% | 1.25% | 22% | $1,566,214 |
Class 4 | |||||||
Year Ended 12/31/2019 | $16.66 | 13.49% | 0.37% | 0.36% | 1.55% | 12% | $1,562,773 |
Year Ended 12/31/2018 | $14.68 | (4.05%) | 0.36% | 0.36% | 1.31% | 10% | $1,578,450 |
Year Ended 12/31/2017 | $15.30 | 9.91% | 0.33% | 0.33% | 1.30% | 4% | $2,000,352 |
Year Ended 12/31/2016 | $13.92 | 4.04% | 0.30% | 0.30% | 1.18% | 8% | $2,217,158 |
Year Ended 12/31/2015 | $13.38 | (0.30%) | 0.28% | 0.28% | 1.25% | 22% | $2,428,436 |
Prospectus 2020 | 89 |
Prospectus 2020 | 91 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $16.92 | 0.21 | 1.39 | 1.60 |
Class 2 | ||||
Year Ended 12/31/2019 | $15.93 | 0.22 | 2.35 | 2.57 |
Year Ended 12/31/2018 | $16.87 | 0.18 | (1.12) | (0.94) |
Year Ended 12/31/2017 | $14.90 | 0.16 | 1.81 | 1.97 |
Year Ended 12/31/2016 | $14.24 | 0.14 | 0.52 | 0.66 |
Year Ended 12/31/2015 | $14.32 | 0.16 | (0.24) | (0.08) |
Class 4 | ||||
Year Ended 12/31/2019 | $15.95 | 0.22 | 2.36 | 2.58 |
Year Ended 12/31/2018 | $16.89 | 0.18 | (1.12) | (0.94) |
Year Ended 12/31/2017 | $14.92 | 0.16 | 1.81 | 1.97 |
Year Ended 12/31/2016 | $14.26 | 0.14 | 0.52 | 0.66 |
Year Ended 12/31/2015 | $14.34 | 0.16 | (0.24) | (0.08) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
92 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $18.52 | 9.46% | 0.10% (d) | 0.10% (d) | 1.38% (d) | 9% | $3,412 |
Class 2 | |||||||
Year Ended 12/31/2019 | $18.50 | 16.13% | 0.35% | 0.35% | 1.23% | 9% | $8,144,403 |
Year Ended 12/31/2018 | $15.93 | (5.57%) | 0.35% | 0.35% | 1.05% | 10% | $7,293,208 |
Year Ended 12/31/2017 | $16.87 | 13.22% | 0.32% | 0.32% | 1.03% | 5% | $8,266,265 |
Year Ended 12/31/2016 | $14.90 | 4.64% | 0.29% | 0.29% | 0.97% | 6% | $7,712,231 |
Year Ended 12/31/2015 | $14.24 | (0.56%) | 0.28% | 0.28% | 1.13% | 23% | $7,690,136 |
Class 4 | |||||||
Year Ended 12/31/2019 | $18.53 | 16.18% | 0.35% | 0.35% | 1.23% | 9% | $9,035,588 |
Year Ended 12/31/2018 | $15.95 | (5.56%) | 0.35% | 0.35% | 1.05% | 10% | $9,032,721 |
Year Ended 12/31/2017 | $16.89 | 13.20% | 0.32% | 0.32% | 1.03% | 5% | $11,144,165 |
Year Ended 12/31/2016 | $14.92 | 4.63% | 0.29% | 0.29% | 0.97% | 6% | $11,452,377 |
Year Ended 12/31/2015 | $14.26 | (0.56%) | 0.28% | 0.28% | 1.13% | 23% | $12,531,242 |
Prospectus 2020 | 93 |
Prospectus 2020 | 95 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $18.37 | 0.18 | 1.71 | 1.89 |
Class 2 | ||||
Year Ended 12/31/2019 | $17.05 | 0.18 | 3.01 | 3.19 |
Year Ended 12/31/2018 | $18.34 | 0.15 | (1.44) | (1.29) |
Year Ended 12/31/2017 | $15.79 | 0.13 | 2.42 | 2.55 |
Year Ended 12/31/2016 | $15.00 | 0.12 | 0.67 | 0.79 |
Year Ended 12/31/2015 | $15.11 | 0.14 | (0.25) | (0.11) |
Class 4 | ||||
Year Ended 12/31/2019 | $17.07 | 0.18 | 3.02 | 3.20 |
Year Ended 12/31/2018 | $18.37 | 0.15 | (1.45) | (1.30) |
Year Ended 12/31/2017 | $15.81 | 0.13 | 2.43 | 2.56 |
Year Ended 12/31/2016 | $15.02 | 0.12 | 0.67 | 0.79 |
Year Ended 12/31/2015 | $15.14 | 0.14 | (0.26) | (0.12) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares are based on operations from February 20, 2019 (commencement of operations) through the stated period end. |
(d) | Annualized. |
96 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $20.26 | 10.29% | 0.12% (d) | 0.12% (d) | 1.11% (d) | 10% | $9,932 |
Class 2 | |||||||
Year Ended 12/31/2019 | $20.24 | 18.71% | 0.37% | 0.37% | 0.97% | 10% | $4,208,417 |
Year Ended 12/31/2018 | $17.05 | (7.03%) | 0.36% | 0.36% | 0.80% | 10% | $4,016,103 |
Year Ended 12/31/2017 | $18.34 | 16.15% | 0.33% | 0.33% | 0.79% | 6% | $4,764,394 |
Year Ended 12/31/2016 | $15.79 | 5.27% | 0.30% | 0.30% | 0.78% | 9% | $4,463,979 |
Year Ended 12/31/2015 | $15.00 | (0.73%) | 0.28% | 0.28% | 0.89% | 24% | $4,668,252 |
Class 4 | |||||||
Year Ended 12/31/2019 | $20.27 | 18.75% | 0.37% | 0.37% | 0.97% | 10% | $3,546,614 |
Year Ended 12/31/2018 | $17.07 | (7.08%) | 0.36% | 0.36% | 0.80% | 10% | $3,625,919 |
Year Ended 12/31/2017 | $18.37 | 16.19% | 0.33% | 0.33% | 0.78% | 6% | $4,658,189 |
Year Ended 12/31/2016 | $15.81 | 5.26% | 0.30% | 0.30% | 0.78% | 9% | $4,841,529 |
Year Ended 12/31/2015 | $15.02 | (0.79%) | 0.28% | 0.28% | 0.88% | 24% | $5,526,022 |
Prospectus 2020 | 97 |
Prospectus 2020 | 99 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $19.79 | 0.14 | 2.09 | 2.23 |
Class 2 | ||||
Year Ended 12/31/2019 | $18.11 | 0.13 | 3.78 | 3.91 |
Year Ended 12/31/2018 | $19.81 | 0.11 | (1.81) | (1.70) |
Year Ended 12/31/2017 | $16.66 | 0.10 | 3.05 | 3.15 |
Year Ended 12/31/2016 | $15.73 | 0.09 | 0.84 | 0.93 |
Year Ended 12/31/2015 | $15.85 | 0.10 | (0.22) | (0.12) |
Class 4 | ||||
Year Ended 12/31/2019 | $18.13 | 0.13 | 3.80 | 3.93 |
Year Ended 12/31/2018 | $19.84 | 0.11 | (1.82) | (1.71) |
Year Ended 12/31/2017 | $16.69 | 0.10 | 3.05 | 3.15 |
Year Ended 12/31/2016 | $15.75 | 0.09 | 0.85 | 0.94 |
Year Ended 12/31/2015 | $15.87 | 0.10 | (0.22) | (0.12) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
100 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $22.02 | 11.27% | 0.11% (d) | 0.11% (d) | 0.78% (d) | 14% | $4,083 |
Class 2 | |||||||
Year Ended 12/31/2019 | $22.02 | 21.59% | 0.36% | 0.36% | 0.64% | 14% | $1,403,662 |
Year Ended 12/31/2018 | $18.11 | (8.58%) | 0.36% | 0.36% | 0.53% | 10% | $1,301,923 |
Year Ended 12/31/2017 | $19.81 | 18.91% | 0.33% | 0.33% | 0.53% | 9% | $1,529,935 |
Year Ended 12/31/2016 | $16.66 | 5.91% | 0.30% | 0.30% | 0.54% | 8% | $1,371,164 |
Year Ended 12/31/2015 | $15.73 | (0.76%) | 0.28% | 0.28% | 0.62% | 26% | $1,418,902 |
Class 4 | |||||||
Year Ended 12/31/2019 | $22.06 | 21.68% | 0.36% | 0.36% | 0.64% | 14% | $1,112,840 |
Year Ended 12/31/2018 | $18.13 | (8.62%) | 0.36% | 0.36% | 0.53% | 10% | $1,079,305 |
Year Ended 12/31/2017 | $19.84 | 18.87% | 0.33% | 0.33% | 0.53% | 9% | $1,384,255 |
Year Ended 12/31/2016 | $16.69 | 5.97% | 0.30% | 0.30% | 0.54% | 8% | $1,414,635 |
Year Ended 12/31/2015 | $15.75 | (0.76%) | 0.28% | 0.28% | 0.61% | 26% | $1,608,428 |
Prospectus 2020 | 101 |
A-1 | Prospectus 2020 |
Prospectus 2020 | A-2 |
A-3 | Prospectus 2020 |
Prospectus 2020 | A-4 |
A-5 | Prospectus 2020 |
Prospectus 2020 | A-6 |
A-7 | Prospectus 2020 |
Prospectus 2020 | A-8 |
A-9 | Prospectus 2020 |
Prospectus 2020 | A-10 |
■ | Buys securities determined to present minimal credit risk by Columbia Management Investment Advisers, LLC (the Investment Manager). |
■ | Limits its U.S. dollar-weighted average portfolio maturity to 60 days or less and its U.S. dollar-weighted average life to 120 days or less. |
■ | Buys obligations with remaining maturities of 397 days or less (as maturity is calculated by SEC rules governing the operation of money market funds). |
■ | Buys only obligations that are denominated in U.S. dollars. |
A-11 | Prospectus 2020 |
Prospectus 2020 | A-12 |
A-13 | Prospectus 2020 |
Prospectus 2020 | A-14 |
A-15 | Prospectus 2020 |
Prospectus 2020 | A-16 |
A-17 | Prospectus 2020 |
Prospectus 2020 | A-18 |
A-19 | Prospectus 2020 |
Prospectus 2020 | B-1 |
B-2 | Prospectus 2020 |
Prospectus 2020 | B-3 |
B-4 | Prospectus 2020 |
Prospectus 2020 | B-5 |
B-6 | Prospectus 2020 |
Prospectus 2020 | B-7 |
B-8 | Prospectus 2020 |
Prospectus 2020 | B-9 |
B-10 | Prospectus 2020 |
Prospectus 2020 | B-11 |
B-12 | Prospectus 2020 |
Prospectus 2020 | B-13 |
B-14 | Prospectus 2020 |
Prospectus 2020 | B-15 |
B-16 | Prospectus 2020 |
Prospectus 2020 | B-17 |
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2 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $67 | $211 | $368 | $ 822 |
Class 2 (whether or not shares are redeemed) | $93 | $290 | $504 | $1,120 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
10 | Prospectus 2020 |
Year
by Year Total Return (%)
as of December 31 Each Year |
Best
and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 2nd Quarter 2016 | 13.14% |
Worst
|
4th Quarter 2014 | -14.88% |
Share
Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 04/30/2013 | 7.80% | -3.98% | -7.20% |
Class 2 | 04/30/2013 | 7.78% | -4.22% | -7.41% |
Bloomberg Commodity Index Total Return (reflects no deductions for fees, expenses or taxes) | 7.69% | -3.92% | -6.48% |
Prospectus 2020 | 11 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Marc Khalamayzer, CFA | Senior Portfolio Manager and Head of Liquid Alternatives | Co-Portfolio Manager | December 2019 | |||
Matthew Ferrelli, CFA | Associate Portfolio Manager | Co-Portfolio Manager | December 2019 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
16 | Prospectus 2020 |
■ | A commodity-linked future is a derivative that is an agreement to buy or sell one or more commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures at a specific date in the future at a specific price. |
■ | A commodity-linked structured note is a derivative (structured investment) that has principal and/or interest payments based on the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), a basket of commodities, indices of commodity futures or other economic variable. If payment of interest on a commodity-linked structured note is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might receive lower interest payments (or not receive any of the interest due) on its investments if there is a loss of value in the underlying reference. Further, to the extent that the amount of principal to be repaid upon maturity is linked to the value of a particular commodity, |
Prospectus 2020 | 17 |
basket of commodities, commodity index or other economic variable, the Fund might not receive a portion (or any) of the principal at maturity of the investment or upon earlier exchange. At any time, the risk of loss associated with a particular structured note in the Fund’s portfolio may be significantly higher than the value of the note. A liquid secondary market may not exist for the commodity-linked structured notes held in the Fund’s portfolio, which may make it difficult for the notes to be sold at a price acceptable to the portfolio manager(s) or for the Fund to accurately value them. |
■ | A commodity-linked swap is a derivative (swap) that is an agreement where the underlying reference is the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures. |
18 | Prospectus 2020 |
Prospectus 2020 | 19 |
20 | Prospectus 2020 |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Prospectus 2020 | 23 |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
Columbia Variable Portfolio – Commodity Strategy Fund | |
Class 1 | 0.80% |
Class 2 | 1.05% |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
28 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Marc Khalamayzer, CFA | Senior Portfolio Manager and Head of Liquid Alternatives | Co-Portfolio Manager | December 2019 | |||
Matthew Ferrelli, CFA | Associate Portfolio Manager | Co-Portfolio Manager | December 2019 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
Prospectus 2020 | 29 |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
30 | Prospectus 2020 |
Prospectus 2020 | 31 |
Class 1 Shares | Class 2 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | |
Investment Limits | none | none |
Conversion Features | none | none |
Front-End Sales Charges | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% |
32 | Prospectus 2020 |
Prospectus 2020 | 33 |
34 | Prospectus 2020 |
Prospectus 2020 | 35 |
36 | Prospectus 2020 |
Prospectus 2020 | 37 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
38 | Prospectus 2020 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. While a fund continues to hold an investment, any gain is generally unrealized. If the fund sells an investment, it generally will realize a capital gain if it sells that investment for a higher price than its adjusted cost basis, and will generally realize a capital loss if it sells that investment for a lower price than its adjusted cost basis. Capital gains and losses are either short-term or long-term, depending on whether the fund holds the securities for one year or less (short-term) or more than one year (long-term). |
Declaration and Distribution Schedule | |
Declarations | Annually |
Distributions | Annually |
Prospectus 2020 | 39 |
40 | Prospectus 2020 |
Prospectus 2020 | 41 |
Net
asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total
from
investment operations |
Distributions
from net investment income |
Total
distributions to shareholders |
|
Class 1 | ||||||
Year Ended 12/31/2019 | $5.21 | 0.08 | 0.33 | 0.41 | (0.07) | (0.07) |
Year Ended 12/31/2018 | $6.05 | 0.07 | (0.90) | (0.83) | (0.01) | (0.01) |
Year Ended 12/31/2017 | $6.33 | 0.01 | 0.07 | 0.08 | (0.36) | (0.36) |
Year Ended 12/31/2016 | $5.61 | (0.02) | 0.74 | 0.72 | — | — |
Year Ended 12/31/2015 | $7.34 | (0.05) | (1.68) | (1.73) | — | — |
Class 2 | ||||||
Year Ended 12/31/2019 | $5.15 | 0.07 | 0.33 | 0.40 | (0.05) | (0.05) |
Year Ended 12/31/2018 | $6.00 | 0.06 | (0.91) | (0.85) | — | — |
Year Ended 12/31/2017 | $6.27 | (0.01) | 0.08 | 0.07 | (0.34) | (0.34) |
Year Ended 12/31/2016 | $5.58 | (0.04) | 0.73 | 0.69 | — | — |
Year Ended 12/31/2015 | $7.32 | (0.07) | (1.67) | (1.74) | — | — |
Notes to Consolidated Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interfund lending expense which is less than 0.01%. |
42 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total
gross
expense ratio to average net assets(a) |
Total
net
expense ratio to average net assets(a), (b) |
Net
investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $5.55 | 7.80% | 0.66% | 0.66% | 1.53% | 0% | $404,193 |
Year Ended 12/31/2018 | $5.21 | (13.77%) | 0.66% (c) | 0.66% (c) | 1.18% | 0% | $226,877 |
Year Ended 12/31/2017 | $6.05 | 1.80% | 0.69% | 0.69% | 0.15% | 0% | $536,624 |
Year Ended 12/31/2016 | $6.33 | 12.83% | 0.74% | 0.74% | (0.39%) | 0% | $481,110 |
Year Ended 12/31/2015 | $5.61 | (23.57%) | 0.88% | 0.88% | (0.77%) | 0% | $42,326 |
Class 2 | |||||||
Year Ended 12/31/2019 | $5.50 | 7.78% | 0.91% | 0.91% | 1.29% | 0% | $16,059 |
Year Ended 12/31/2018 | $5.15 | (14.17%) | 0.92% (c) | 0.92% (c) | 1.05% | 0% | $15,269 |
Year Ended 12/31/2017 | $6.00 | 1.71% | 0.94% | 0.94% | (0.09%) | 0% | $15,541 |
Year Ended 12/31/2016 | $6.27 | 12.37% | 0.99% | 0.99% | (0.63%) | 0% | $10,540 |
Year Ended 12/31/2015 | $5.58 | (23.77%) | 1.15% | 1.15% | (1.02%) | 0% | $3,550 |
Prospectus 2020 | 43 |
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2 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) indefinitely. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rate of 0.40%. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Columbia Variable Portfolio – Core Equity Fund | $41 | $128 | $224 | $505 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2012 | 14.77% |
Worst
|
4th Quarter 2018 | -13.62% |
Inception Date | 1 Year | 5 Years | 10 Years | |
Columbia Variable Portfolio – Core Equity Fund | 09/10/2004 | 25.18% | 10.69% | 14.22% |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.70% | 13.56% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Condon, CFA, CAIA* | Senior Portfolio Manager and Head of Quantitative Strategies | Co-Portfolio Manager | 2010 | |||
Peter Albanese | Senior Portfolio Manager | Co-Portfolio Manager | 2014 | |||
Raghavendran Sivaraman, Ph.D., CFA | Senior Portfolio Manager | Co-Portfolio Manager | December 2019 |
* | Brian Condon has announced that he plans to retire from the Investment Manager, on May 31, 2020. Until then, Mr. Condon will continue to serve as a Co-Portfolio Manager of the Fund. |
Prospectus 2020 | 7 |
■ | Valuation factors, such as earnings and cash flow relative to market values; |
■ | Catalyst factors, such as relative stock price performance, business momentum, and short interest measures; and |
■ | Quality factors, such as quality of earnings and financial strength. |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
10 | Prospectus 2020 |
Prospectus 2020 | 11 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Columbia Variable Portfolio – Core Equity Fund | |
0.40% |
Prospectus 2020 | 15 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Condon, CFA, CAIA* | Senior Portfolio Manager and Head of Quantitative Strategies | Co-Portfolio Manager | 2010 | |||
Peter Albanese | Senior Portfolio Manager | Co-Portfolio Manager | 2014 | |||
Raghavendran Sivaraman, Ph.D., CFA | Senior Portfolio Manager | Co-Portfolio Manager | December 2019 |
16 | Prospectus 2020 |
* | Brian Condon has announced that he plans to retire from the Investment Manager, on May 31, 2020. Until then, Mr. Condon will continue to serve as a Co-Portfolio Manager of the Fund. |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
Prospectus 2020 | 17 |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
18 | Prospectus 2020 |
Eligible Investors | The Fund is available exclusively as an underlying investment option of variable annuity contracts offered by RiverSource Life Insurance Company | |
Investment Limits | none | |
Conversion Features | none | |
Front-End Sales Charges | none | |
Contingent Deferred Sales Charges (CDSCs) | none | |
Maximum Distribution and/or Service Fees | none |
Prospectus 2020 | 19 |
20 | Prospectus 2020 |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Prospectus 2020 | 23 |
24 | Prospectus 2020 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
Prospectus 2020 | 25 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
28 | Prospectus 2020 |
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3 |
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3 |
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3 |
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10 |
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36 |
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39 |
2 | Prospectus 2020 |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $78 | $243 | $422 | $942 |
Class 2 (whether or not shares are redeemed) | $103 | $322 | $558 | $1,236 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.61% |
Worst
|
2nd Quarter 2013 | -7.07% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 04/30/2012 | 12.35% | 5.18% | 4.01% |
Class 2 | 04/30/2012 | 12.09% | 4.91% | 3.75% |
JPMorgan Emerging Markets Bond Index-Global (reflects no deductions for fees, expenses or taxes) | 14.42% | 5.88% | 5.03% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Tim Jagger | Head of Emerging Market Debt and Senior Portfolio Manager | Lead Portfolio Manager | 2019 | |||
Christopher Cooke | Deputy Portfolio Manager | Portfolio Manager | 2017 |
10 | Prospectus 2020 |
Prospectus 2020 | 11 |
■ | Analyzing the creditworthiness of emerging market countries; |
■ | Seeking to evaluate the best relative value opportunities among emerging market countries, by comparing sovereign debt spreads to fundamental creditworthiness and comparing the recent sovereign debt spread relationships among countries to historic relationships; and |
■ | Seeking to identify emerging markets bonds that can take advantage of attractive local interest rates and provide exposure to undervalued currencies. |
■ | The security is overvalued; |
12 | Prospectus 2020 |
■ | The security has new credit risks; or |
■ | The security continues to meet the standards described above. |
Prospectus 2020 | 13 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency strategy by a Fund may be reduced by the Fund's inability to precisely match forward |
14 | Prospectus 2020 |
contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to |
Prospectus 2020 | 15 |
bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
16 | Prospectus 2020 |
Prospectus 2020 | 17 |
18 | Prospectus 2020 |
Prospectus 2020 | 19 |
20 | Prospectus 2020 |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Prospectus 2020 | 23 |
Columbia Variable Portfolio - Emerging Markets Bond Fund | |
Class 1 | 0.83% |
Class 2 | 1.08% |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Tim Jagger | Head of Emerging Market Debt and Senior Portfolio Manager | Lead Portfolio Manager | 2019 | |||
Christopher Cooke | Deputy Portfolio Manager | Portfolio Manager | 2017 |
26 | Prospectus 2020 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
Prospectus 2020 | 27 |
28 | Prospectus 2020 |
Class 1 Shares | Class 2 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | |
Investment Limits | none | none |
Conversion Features | none | none |
Front-End Sales Charges | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% |
Prospectus 2020 | 29 |
30 | Prospectus 2020 |
Prospectus 2020 | 31 |
32 | Prospectus 2020 |
Prospectus 2020 | 33 |
34 | Prospectus 2020 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
Prospectus 2020 | 35 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. While a fund continues to hold an investment, any gain is generally unrealized. If the fund sells an investment, it generally will realize a capital gain if it sells that investment for a higher price than its adjusted cost basis, and will generally realize a capital loss if it sells that investment for a lower price than its adjusted cost basis. Capital gains and losses are either short-term or long-term, depending on whether the fund holds the securities for one year or less (short-term) or more than one year (long-term). |
Declaration and Distribution Schedule | |
Declarations | Quarterly |
Distributions | Quarterly |
36 | Prospectus 2020 |
Prospectus 2020 | 37 |
Prospectus 2020 | 39 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net investment income |
Total
distributions to shareholders |
|
Class 1 | ||||||
Year Ended 12/31/2019 | $9.01 | 0.50 | 0.60 | 1.10 | (0.49) | (0.49) |
Year Ended 12/31/2018 | $10.15 | 0.53 | (1.23) | (0.70) | (0.44) | (0.44) |
Year Ended 12/31/2017 | $9.50 | 0.59 | 0.52 | 1.11 | (0.46) | (0.46) |
Year Ended 12/31/2016 | $8.77 | 0.55 | 0.43 | 0.98 | (0.25) | (0.25) |
Year Ended 12/31/2015 | $9.01 | 0.52 | (0.61) | (0.09) | (0.15) | (0.15) |
Class 2 | ||||||
Year Ended 12/31/2019 | $9.00 | 0.47 | 0.61 | 1.08 | (0.47) | (0.47) |
Year Ended 12/31/2018 | $10.15 | 0.51 | (1.25) | (0.74) | (0.41) | (0.41) |
Year Ended 12/31/2017 | $9.49 | 0.57 | 0.52 | 1.09 | (0.43) | (0.43) |
Year Ended 12/31/2016 | $8.76 | 0.53 | 0.43 | 0.96 | (0.23) | (0.23) |
Year Ended 12/31/2015 | $9.02 | 0.49 | (0.60) | (0.11) | (0.15) | (0.15) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interest on collateral expense which is less than 0.01%. |
40 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $9.62 | 12.35% | 0.76% | 0.76% | 5.21% | 137% | $117,692 |
Year Ended 12/31/2018 | $9.01 | (7.04%) | 0.76% (c) | 0.76% (c) | 5.53% | 64% | $103,590 |
Year Ended 12/31/2017 | $10.15 | 11.85% | 0.75% | 0.75% | 5.88% | 42% | $110,275 |
Year Ended 12/31/2016 | $9.50 | 11.34% | 0.75% | 0.75% | 5.92% | 26% | $98,824 |
Year Ended 12/31/2015 | $8.77 | (1.03%) | 0.75% | 0.75% | 5.77% | 64% | $87,659 |
Class 2 | |||||||
Year Ended 12/31/2019 | $9.61 | 12.09% | 1.01% | 1.01% | 4.94% | 137% | $203,064 |
Year Ended 12/31/2018 | $9.00 | (7.38%) | 1.02% (c) | 1.02% (c) | 5.32% | 64% | $121,570 |
Year Ended 12/31/2017 | $10.15 | 11.69% | 1.01% | 1.01% | 5.70% | 42% | $94,637 |
Year Ended 12/31/2016 | $9.49 | 11.07% | 1.01% | 1.01% | 5.63% | 26% | $40,731 |
Year Ended 12/31/2015 | $8.76 | (1.31%) | 1.01% | 1.01% | 5.49% | 64% | $16,653 |
Prospectus 2020 | 41 |
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21 |
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22 |
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24 |
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28 |
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28 |
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28 |
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31 |
2 | Prospectus 2020 |
(a) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.69% for Class 1 and 0.94% for Class 2. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $70 | $232 | $407 | $914 |
Class 2 (whether or not shares are redeemed) | $96 | $310 | $542 | $1,208 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 12.84% |
Worst
|
3rd Quarter 2019 | 0.00% |
Share Class
Inception Date |
1 Year | Life of Fund | |
Class 1 | 01/04/2018 | 27.99% | 9.09% |
Class 2 | 01/04/2018 | 27.62% | 8.82% |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 11.13% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Peter Santoro, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2018 |
Prospectus 2020 | 7 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Melda Mergen, CFA, CAIA | Senior Portfolio Manager, Managing Director and Deputy Global Head of Equities | Co-Portfolio Manager | 2018 | |||
Tiffany Wade | Portfolio Manager | Co-Portfolio Manager | November 2019 |
8 | Prospectus 2020 |
■ | overall economic and market conditions; and |
■ | the financial condition and management of a company, including its competitive position, the quality of its balance sheet and earnings, its future prospects, and the potential for growth and stock price appreciation. |
Prospectus 2020 | 9 |
10 | Prospectus 2020 |
Prospectus 2020 | 11 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
16 | Prospectus 2020 |
Columbia Variable Portfolio - Select Large Cap Equity Fund | |
Class 1 | 0.69% |
Class 2 | 0.94% |
Prospectus 2020 | 17 |
18 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Peter Santoro, CFA | Senior Portfolio Manager | Co-Portfolio Manager | 2018 | |||
Melda Mergen, CFA, CAIA | Senior Portfolio Manager, Managing Director and Deputy Global Head of Equities | Co-Portfolio Manager | 2018 | |||
Tiffany Wade | Portfolio Manager | Co-Portfolio Manager | November 2019 |
Prospectus 2020 | 19 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
20 | Prospectus 2020 |
Class 1 Shares | Class 2 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | |
Investment Limits | none | none |
Conversion Features | none | none |
Front-End Sales Charges | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Prospectus 2020 | 23 |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
26 | Prospectus 2020 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
Prospectus 2020 | 27 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. |
28 | Prospectus 2020 |
Prospectus 2020 | 29 |
Prospectus 2020 | 31 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019 | $9.29 | 0.13 | 2.47 | 2.60 |
Year Ended 12/31/2018(c) | $10.00 | 0.13 | (0.84) | (0.71) |
Class 2 | ||||
Year Ended 12/31/2019 | $9.27 | 0.10 | 2.46 | 2.56 |
Year Ended 12/31/2018(c) | $10.00 | 0.09 | (0.82) | (0.73) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | The Fund commenced operations on January 4, 2018. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
32 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $11.89 | 27.99% | 0.74% | 0.69% | 1.25% | 59% | $1,347,827 |
Year Ended 12/31/2018(c) | $9.29 | (7.10%) | 0.75% (d) | 0.69% (d) | 1.27% (d) | 58% | $1,070,480 |
Class 2 | |||||||
Year Ended 12/31/2019 | $11.83 | 27.62% | 0.97% | 0.94% | 0.97% | 59% | $3 |
Year Ended 12/31/2018(c) | $9.27 | (7.30%) | 0.97% (d) | 0.94% (d) | 0.84% (d) | 58% | $2 |
Prospectus 2020 | 33 |
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30 |
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30 |
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30 |
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33 |
2 | Prospectus 2020 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2021, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 0.99% for Class 1 and 1.24% for Class 2. |
■ | you invest $10,000 in the applicable class of Fund shares for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $101 | $354 | $626 | $1,404 |
Class 2 (whether or not shares are redeemed) | $126 | $432 | $759 | $1,686 |
Prospectus 2020 | 3 |
4 | Prospectus 2020 |
Prospectus 2020 | 5 |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 22.96% |
Worst
|
4th Quarter 2018 | -15.52% |
Share Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/01/1996 | 55.31% | 20.44% | 16.66% |
Class 2 | 05/01/2000 | 54.97% | 20.13% | 16.35% |
MSCI World Information Technology Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 47.55% | 18.33% | 15.52% |
Portfolio Manager | Role with Fund | Managed Fund Since | ||
Paul Wick | Lead Portfolio Manager | 2006 | ||
Shekhar Pramanick | Portfolio Manager | 2014 | ||
Sanjay Devgan | Technology Team Member | 2014 | ||
Jeetil Patel | Technology Team Member | 2015 | ||
Christopher Boova | Technology Team Member | 2016 | ||
Vimal Patel | Technology Team Member | 2018 |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
■ | Above-average growth prospects; |
■ | High profit margins; |
■ | Attractive valuations relative to earnings forecasts or other valuation criteria (e.g., return on equity); |
■ | Quality management and equity ownership by executives; |
■ | Unique competitive advantages (e.g., market share, proprietary products); or |
■ | Potential for improvement in overall operations. |
10 | Prospectus 2020 |
■ | Its target price has been reached; |
■ | Its earnings are disappointing; |
■ | Its revenue growth has slowed; |
■ | Its underlying fundamentals have deteriorated; or |
■ | If the Investment Manager believes that negative country or regional factors may affect a company’s outlook. |
Prospectus 2020 | 11 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
16 | Prospectus 2020 |
Prospectus 2020 | 17 |
Columbia Variable Portfolio - Seligman Global Technology Fund | |
Class 1 | 0.99% |
Class 2 | 1.24% |
18 | Prospectus 2020 |
Prospectus 2020 | 19 |
Portfolio Manager | Role with Fund | Managed Fund Since | ||
Paul Wick | Lead Portfolio Manager | 2006 | ||
Shekhar Pramanick | Portfolio Manager | 2014 | ||
Sanjay Devgan | Technology Team Member | 2014 | ||
Jeetil Patel | Technology Team Member | 2015 | ||
Christopher Boova | Technology Team Member | 2016 | ||
Vimal Patel | Technology Team Member | 2018 |
20 | Prospectus 2020 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Class 1 Shares | Class 2 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | |
Investment Limits | none | none |
Conversion Features | none | none |
Front-End Sales Charges | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% |
Prospectus 2020 | 23 |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
28 | Prospectus 2020 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
Prospectus 2020 | 29 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. While a fund continues to hold an investment, any gain is generally unrealized. If the fund sells an investment, it generally will realize a capital gain if it sells that investment for a higher price than its adjusted cost basis, and will generally realize a capital loss if it sells that investment for a lower price than its adjusted cost basis. Capital gains and losses are either short-term or long-term, depending on whether the fund holds the securities for one year or less (short-term) or more than one year (long-term). |
Declaration and Distribution Schedule | |
Declarations | Annually |
Distributions | Annually |
30 | Prospectus 2020 |
Prospectus 2020 | 31 |
Prospectus 2020 | 33 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
Distributions
from net realized gains |
Total
distributions to shareholders |
|
Class 1 | ||||||
Year Ended 12/31/2019 | $17.78 | 0.02 | 9.00 | 9.02 | (3.44) | (3.44) |
Year Ended 12/31/2018 | $21.56 | 0.01 | (1.47) | (1.46) | (2.32) | (2.32) |
Year Ended 12/31/2017 | $21.67 | (0.03) | 6.79 | 6.76 | (6.87) | (6.87) |
Year Ended 12/31/2016 | $27.97 | (0.04) | 3.55 | 3.51 | (9.81) | (9.81) |
Year Ended 12/31/2015 | $29.99 | (0.01) | 3.00 | 2.99 | (5.01) | (5.01) |
Class 2 | ||||||
Year Ended 12/31/2019 | $16.33 | (0.03) | 8.20 | 8.17 | (3.38) | (3.38) |
Year Ended 12/31/2018 | $19.99 | (0.04) | (1.35) | (1.39) | (2.27) | (2.27) |
Year Ended 12/31/2017 | $20.50 | (0.08) | 6.38 | 6.30 | (6.81) | (6.81) |
Year Ended 12/31/2016 | $26.98 | (0.12) | 3.38 | 3.26 | (9.74) | (9.74) |
Year Ended 12/31/2015 | $29.10 | (0.08) | 2.91 | 2.83 | (4.95) | (4.95) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interfund lending expense which is less than 0.01%. |
(d) | Ratios include line of credit interest expense which is less than 0.01%. |
34 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019 | $23.36 | 55.31% | 1.18% (c) | 0.97% (c) | 0.09% | 56% | $44,565 |
Year Ended 12/31/2018 | $17.78 | (8.15%) | 1.09% (c), (d) | 1.03% (c), (d) | 0.05% | 44% | $32,129 |
Year Ended 12/31/2017 | $21.56 | 35.21% | 1.15% (d) | 1.02% (d) | (0.16%) | 60% | $38,879 |
Year Ended 12/31/2016 | $21.67 | 19.35% | 1.26% | 0.98% | (0.17%) | 62% | $31,083 |
Year Ended 12/31/2015 | $27.97 | 10.11% | 1.20% | 0.98% | (0.05%) | 65% | $28,698 |
Class 2 | |||||||
Year Ended 12/31/2019 | $21.12 | 54.97% | 1.43% (c) | 1.21% (c) | (0.15%) | 56% | $57,023 |
Year Ended 12/31/2018 | $16.33 | (8.45%) | 1.33% (c), (d) | 1.28% (c), (d) | (0.22%) | 44% | $33,975 |
Year Ended 12/31/2017 | $19.99 | 34.92% | 1.40% (d) | 1.27% (d) | (0.39%) | 60% | $46,688 |
Year Ended 12/31/2016 | $20.50 | 19.01% | 1.47% | 1.23% | (0.49%) | 62% | $27,838 |
Year Ended 12/31/2015 | $26.98 | 9.81% | 1.45% | 1.23% | (0.30%) | 65% | $83,566 |
Prospectus 2020 | 35 |
SUMMARIES OF THE FUNDS
Investment Objective, Fees and Expenses of the Fund, Principal Investment Strategies, Principal Risks, Performance Information, Fund Management, Purchase and Sale of Fund Shares, Tax Information, Payments to Broker-Dealers and Other Financial Intermediaries |
|
|
4 |
|
18 |
|
31 |
|
45 |
|
59 |
|
73 |
|
87 |
|
100 |
|
113 |
|
126 |
|
141 |
|
155 |
|
170 |
|
185 |
|
200 |
|
215 |
|
229 |
|
243 |
|
257 |
|
257 |
|
261 |
|
264 |
|
265 |
|
266 |
|
266 |
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266 |
|
267 |
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269 |
|
274 |
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274 |
|
274 |
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277 |
|
281 |
|
285 |
|
289 |
|
293 |
|
297 |
|
301 |
|
305 |
|
309 |
2 | Prospectus 2020 |
Prospectus 2020 | 3 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $81 | $252 | $439 | $978 |
Class 2 (whether or not shares are redeemed) | $106 | $331 | $574 | $1,271 |
4 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 5 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
6 | Prospectus 2020 |
Prospectus 2020 | 7 |
8 | Prospectus 2020 |
Prospectus 2020 | 9 |
10 | Prospectus 2020 |
Prospectus 2020 | 11 |
12 | Prospectus 2020 |
Prospectus 2020 | 13 |
14 | Prospectus 2020 |
Prospectus 2020 | 15 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.72% |
Worst
|
4th Quarter 2018 | -7.61% |
Share Class
Inception Date |
1 Year | Life of Fund | |
Class 1 | 02/20/2019 | 16.37% | 6.06% |
Class 2 | 09/12/2017 | 16.06% | 5.94% |
Blended Benchmark (consisting of 50% Bloomberg Barclays U.S. Aggregate Bond Index, 35% Russell 3000 Index and 15% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 18.41% | 7.43% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.74% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 13.50% | |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | 22.01% | 4.25% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2017 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2017 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2017 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
16 | Prospectus 2020 |
Prospectus 2020 | 17 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $79 | $246 | $428 | $954 |
Class 2 (whether or not shares are redeemed) | $104 | $325 | $563 | $1,248 |
18 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 19 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
20 | Prospectus 2020 |
Prospectus 2020 | 21 |
22 | Prospectus 2020 |
Prospectus 2020 | 23 |
24 | Prospectus 2020 |
Prospectus 2020 | 25 |
26 | Prospectus 2020 |
Prospectus 2020 | 27 |
28 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 8.02% |
Worst
|
4th Quarter 2018 | -7.68% |
Share Class
Inception Date |
1 Year | Life of Fund | |
Class 1 | 02/20/2019 | 18.63% | 8.17% |
Class 2 | 09/12/2017 | 18.32% | 8.05% |
Blended Benchmark (consisting of 50% Bloomberg Barclays U.S. Aggregate Bond Index and 50% S&P 500 Index) (reflects no deductions for fees, expenses or taxes) | 19.89% | 9.08% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.74% | |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 14.08% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2017 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2017 |
Prospectus 2020 | 29 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2017 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
30 | Prospectus 2020 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $73 | $227 | $395 | $883 |
Class 2 (whether or not shares are redeemed) | $98 | $306 | $531 | $1,178 |
Prospectus 2020 | 31 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
32 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 33 |
34 | Prospectus 2020 |
Prospectus 2020 | 35 |
36 | Prospectus 2020 |
Prospectus 2020 | 37 |
38 | Prospectus 2020 |
Prospectus 2020 | 39 |
40 | Prospectus 2020 |
Prospectus 2020 | 41 |
42 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 4.94% |
Worst
|
4th Quarter 2018 | -2.50% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 12.19% | 3.74% | 3.63% |
Class 2 | 04/12/2013 | 11.91% | 3.69% | 3.60% |
Blended Benchmark (consisting of 80% Bloomberg Barclays U.S. Aggregate Bond Index, 14% Russell 3000 Index and 6% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 12.57% | 4.46% | 4.41% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 2.73% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2014 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 43 |
44 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $76 | $237 | $411 | $918 |
Class 2 (whether or not shares are redeemed) | $101 | $315 | $547 | $1,213 |
Prospectus 2020 | 45 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
46 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 47 |
48 | Prospectus 2020 |
Prospectus 2020 | 49 |
50 | Prospectus 2020 |
Prospectus 2020 | 51 |
52 | Prospectus 2020 |
Prospectus 2020 | 53 |
54 | Prospectus 2020 |
Prospectus 2020 | 55 |
56 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 6.36% |
Worst
|
4th Quarter 2018 | -5.22% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 14.34% | 4.27% | 4.54% |
Class 2 | 04/12/2013 | 14.00% | 4.20% | 4.50% |
Blended Benchmark (consisting of 65% Bloomberg Barclays U.S. Aggregate Bond Index, 24% Russell 3000 Index and 11% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or other taxes) | 15.44% | 5.46% | 5.61% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 2.73% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2014 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 57 |
58 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $79 | $246 | $428 | $954 |
Class 2 (whether or not shares are redeemed) | $104 | $325 | $563 | $1,248 |
Prospectus 2020 | 59 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
60 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 61 |
62 | Prospectus 2020 |
Prospectus 2020 | 63 |
64 | Prospectus 2020 |
Prospectus 2020 | 65 |
66 | Prospectus 2020 |
Prospectus 2020 | 67 |
68 | Prospectus 2020 |
Prospectus 2020 | 69 |
70 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 9.25% |
Worst
|
4th Quarter 2018 | -10.60% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 18.52% | 5.12% | 6.21% |
Class 2 | 04/12/2013 | 18.26% | 5.07% | 6.18% |
Blended Benchmark (consisting of 46% Russell 3000 Index, 35% Bloomberg Barclays U.S. Aggregate Bond Index and 19% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or taxes) | 21.40% | 7.49% | 8.10% | |
Russell 3000 Index (reflects no deductions for fees, expenses or taxes) | 31.02% | 11.24% | 13.06% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2014 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 71 |
72 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $75 | $233 | $406 | $906 |
Class 2 (whether or not shares are redeemed) | $100 | $312 | $542 | $1,201 |
Prospectus 2020 | 73 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
74 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 75 |
76 | Prospectus 2020 |
Prospectus 2020 | 77 |
78 | Prospectus 2020 |
Prospectus 2020 | 79 |
80 | Prospectus 2020 |
Prospectus 2020 | 81 |
82 | Prospectus 2020 |
Prospectus 2020 | 83 |
84 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.78% |
Worst
|
4th Quarter 2018 | -7.93% |
Share Class
Inception Date |
1 Year | 5 Years | Life of Fund | |
Class 1 | 02/20/2019 | 16.41% | 4.79% | 5.90% |
Class 2 | 04/19/2012 | 16.17% | 4.74% | 5.87% |
Blended Benchmark (consisting of 50% Bloomberg Barclays U.S. Aggregate Bond Index, 35% Russell 3000 Index and 15% MSCI EAFE Index (Net)) (reflects reinvested dividends net of withholding taxes on the MSCI EAFE Index portion of the Blended Benchmark, and for all indexes reflects no deductions for fees, expenses or taxes) | 18.41% | 6.49% | 7.40% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | 2.85% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2014 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2015 | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 85 |
86 | Prospectus 2020 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
(b) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $73 | $227 | $395 | $883 |
Class 2 (whether or not shares are redeemed) | $98 | $306 | $531 | $1,178 |
Prospectus 2020 | 87 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
88 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 89 |
90 | Prospectus 2020 |
Prospectus 2020 | 91 |
92 | Prospectus 2020 |
Prospectus 2020 | 93 |
94 | Prospectus 2020 |
Prospectus 2020 | 95 |
96 | Prospectus 2020 |
Prospectus 2020 | 97 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 6.29% |
Worst
|
4th Quarter 2018 | -4.94% |
Share Class
Inception Date |
1 Year | Life of Fund | |
Class 1 | 02/20/2019 | 15.13% | 7.66% |
Class 2 | 11/02/2016 | 14.86% | 7.58% |
Blended Benchmark (consisting of 65% Bloomberg Barclays U.S. Aggregate Bond Index and 35% S&P 500 Index) (reflects no deductions for fees, expenses or taxes) | 16.49% | 7.94% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 16.97% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2016 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2016 |
98 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 99 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $73 | $227 | $395 | $883 |
Class 2 (whether or not shares are redeemed) | $98 | $306 | $531 | $1,178 |
100 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 101 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
102 | Prospectus 2020 |
Prospectus 2020 | 103 |
104 | Prospectus 2020 |
Prospectus 2020 | 105 |
106 | Prospectus 2020 |
Prospectus 2020 | 107 |
108 | Prospectus 2020 |
Prospectus 2020 | 109 |
110 | Prospectus 2020 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 8.83% |
Worst
|
4th Quarter 2018 | -9.59% |
Share Class
Inception Date |
1 Year | Life of Fund | |
Class 1 | 02/20/2019 | 20.55% | 11.73% |
Class 2 | 11/02/2016 | 20.20% | 11.63% |
Blended Benchmark (consisting of 65% S&P 500 Index and 35% Bloomberg Barclays U.S. Aggregate Bond Index) (reflects no deductions for fees, expenses or taxes) | 23.33% | 12.13% | |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 16.97% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2016 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2016 |
Prospectus 2020 | 111 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
112 | Prospectus 2020 |
(a) | “Total annual Fund operating expenses” include acquired fund fees and expenses (expenses the Fund incurs indirectly through its investments in other investment companies) and may be higher than the ratio of expenses to average net assets shown in the Financial Highlights section of this prospectus because the ratio of expenses to average net assets does not include acquired fund fees and expenses. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $72 | $224 | $390 | $871 |
Class 2 (whether or not shares are redeemed) | $97 | $303 | $525 | $1,166 |
Prospectus 2020 | 113 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
114 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 115 |
116 | Prospectus 2020 |
Prospectus 2020 | 117 |
118 | Prospectus 2020 |
Prospectus 2020 | 119 |
120 | Prospectus 2020 |
Prospectus 2020 | 121 |
122 | Prospectus 2020 |
Prospectus 2020 | 123 |
Year by Year Total Return (%)
as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
|
Best | 1st Quarter 2019 | 7.56% |
Worst
|
4th Quarter 2018 | -7.25% |
Share Class
Inception Date |
1 Year | Life of Fund | |
Class 1 | 02/20/2019 | 17.84% | 9.72% |
Class 2 | 11/02/2016 | 17.57% | 9.65% |
Blended Benchmark (consisting of 50% S&P 500 Index and 50% Bloomberg Barclays U.S. Aggregate Bond Index) (reflects no deductions for fees, expenses or taxes) | 19.89% | 10.04% | |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) | 8.72% | 3.05% | |
S&P 500 Index (reflects no deductions for fees, expenses or taxes) | 31.49% | 16.97% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments | Lead Portfolio Manager | 2016 | |||
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy | Portfolio Manager | 2016 |
124 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
David Weiss, CFA | Vice President, Head of Sub-Advisory Management | Portfolio Manager | 2016 | |||
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation | Portfolio Manager | 2018 |
Prospectus 2020 | 125 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
126 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 127 |
128 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Emerging Markets Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Overseas Core Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Lazard International Equity Advantage Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP®– T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners International Core Equity Fund (formerly known as CTIVP® - AQR International Core Equity Fund), Variable Portfolio – Partners International Growth Fund (formerly known as CTIVP® - William Blair International Leaders Fund), Variable Portfolio – Partners International Value Fund (formerly known as CTIVP® - DFA International Value Fund), Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio– Emerging Markets Bond Fund, Columbia Variable Portfolio – Global Strategic Income Fund, Columbia
Variable Portfolio– High Yield Bond Fund, Columbia Variable Portfolio– Income Opportunities Fund, Columbia Variable Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited
Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio – Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund,
CTIVP® – American Century Diversified Bond Fund, CTIVP® – BlackRock Global Inflation-Protected Securities Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
Prospectus 2020 | 129 |
130 | Prospectus 2020 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
Prospectus 2020 | 131 |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a |
132 | Prospectus 2020 |
credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 133 |
134 | Prospectus 2020 |
Prospectus 2020 | 135 |
136 | Prospectus 2020 |
Prospectus 2020 | 137 |
138 | Prospectus 2020 |
Prospectus 2020 | 139 |
140 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 141 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
142 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP® – T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Prospectus 2020 | 143 |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio – High Yield Bond Fund, Columbia Variable Portfolio – Income Opportunities Fund, Columbia Variable
Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio –
Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund, CTIVP® – American Century Diversified Bond Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
144 | Prospectus 2020 |
Prospectus 2020 | 145 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
146 | Prospectus 2020 |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 147 |
148 | Prospectus 2020 |
Prospectus 2020 | 149 |
150 | Prospectus 2020 |
Prospectus 2020 | 151 |
152 | Prospectus 2020 |
Prospectus 2020 | 153 |
154 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 155 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
156 | Prospectus 2020 |
Prospectus 2020 | 157 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Emerging Markets Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Overseas Core Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, Columbia Variable Portfolio – Small Cap Value Fund, Columbia Variable Portfolio – Small Company Growth Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Lazard International Equity Advantage Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP®– T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners International Core Equity Fund (formerly known as CTIVP® - AQR International Core Equity Fund), Variable Portfolio – Partners International Growth Fund (formerly known as CTIVP® - William Blair International Leaders Fund), Variable Portfolio – Partners International Value Fund (formerly known as CTIVP® - DFA International Value Fund), Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio– Emerging Markets Bond Fund, Columbia Variable Portfolio – Global Strategic Income Fund, Columbia
Variable Portfolio– High Yield Bond Fund, Columbia Variable Portfolio– Income Opportunities Fund, Columbia Variable Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited
Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio – Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund,
CTIVP® – American Century Diversified Bond Fund, CTIVP® – BlackRock Global Inflation-Protected Securities Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
158 | Prospectus 2020 |
Prospectus 2020 | 159 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
160 | Prospectus 2020 |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect |
Prospectus 2020 | 161 |
performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
162 | Prospectus 2020 |
Prospectus 2020 | 163 |
164 | Prospectus 2020 |
Prospectus 2020 | 165 |
166 | Prospectus 2020 |
Prospectus 2020 | 167 |
168 | Prospectus 2020 |
Prospectus 2020 | 169 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
170 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 171 |
172 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Emerging Markets Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Overseas Core Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, Columbia Variable Portfolio – Small Cap Value Fund, Columbia Variable Portfolio – Small Company Growth Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Lazard International Equity Advantage Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP®– T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners International Core Equity Fund (formerly known as CTIVP® - AQR International Core Equity Fund), Variable Portfolio – Partners International Growth Fund (formerly known as CTIVP® - William Blair International Leaders Fund), Variable Portfolio – Partners International Value Fund (formerly known as CTIVP® - DFA International Value Fund), Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio– Emerging Markets Bond Fund, Columbia Variable Portfolio – Global Strategic Income Fund, Columbia
Variable Portfolio– High Yield Bond Fund, Columbia Variable Portfolio– Income Opportunities Fund, Columbia Variable Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited
Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio – Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund,
CTIVP® – American Century Diversified Bond Fund, CTIVP® – BlackRock Global Inflation-Protected Securities Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
Prospectus 2020 | 173 |
174 | Prospectus 2020 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
Prospectus 2020 | 175 |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a |
176 | Prospectus 2020 |
credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 177 |
178 | Prospectus 2020 |
Prospectus 2020 | 179 |
180 | Prospectus 2020 |
Prospectus 2020 | 181 |
182 | Prospectus 2020 |
Prospectus 2020 | 183 |
184 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 185 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
186 | Prospectus 2020 |
Prospectus 2020 | 187 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Emerging Markets Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Overseas Core Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, Columbia Variable Portfolio – Small Cap Value Fund, Columbia Variable Portfolio – Small Company Growth Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Lazard International Equity Advantage Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP®– T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners International Core Equity Fund (formerly known as CTIVP® - AQR International Core Equity Fund), Variable Portfolio – Partners International Growth Fund (formerly known as CTIVP® - William Blair International Leaders Fund), Variable Portfolio – Partners International Value Fund (formerly known as CTIVP® - DFA International Value Fund), Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio– Emerging Markets Bond Fund, Columbia Variable Portfolio – Global Strategic Income Fund, Columbia
Variable Portfolio– High Yield Bond Fund, Columbia Variable Portfolio– Income Opportunities Fund, Columbia Variable Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited
Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio – Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund,
CTIVP® – American Century Diversified Bond Fund, CTIVP® – BlackRock Global Inflation-Protected Securities Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
188 | Prospectus 2020 |
Prospectus 2020 | 189 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
190 | Prospectus 2020 |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a |
Prospectus 2020 | 191 |
credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
192 | Prospectus 2020 |
Prospectus 2020 | 193 |
194 | Prospectus 2020 |
Prospectus 2020 | 195 |
196 | Prospectus 2020 |
Prospectus 2020 | 197 |
198 | Prospectus 2020 |
Prospectus 2020 | 199 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, sovereign debt, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, international bonds and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
200 | Prospectus 2020 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
Prospectus 2020 | 201 |
202 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Emerging Markets Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Overseas Core Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, Columbia Variable Portfolio – Small Cap Value Fund, Columbia Variable Portfolio – Small Company Growth Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Lazard International Equity Advantage Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP®– T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners International Core Equity Fund (formerly known as CTIVP® - AQR International Core Equity Fund), Variable Portfolio – Partners International Growth Fund (formerly known as CTIVP® - William Blair International Leaders Fund), Variable Portfolio – Partners International Value Fund (formerly known as CTIVP® - DFA International Value Fund), Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio– Emerging Markets Bond Fund, Columbia Variable Portfolio – Global Strategic Income Fund, Columbia
Variable Portfolio– High Yield Bond Fund, Columbia Variable Portfolio– Income Opportunities Fund, Columbia Variable Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited
Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio – Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund,
CTIVP® – American Century Diversified Bond Fund, CTIVP® – BlackRock Global Inflation-Protected Securities Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
Prospectus 2020 | 203 |
204 | Prospectus 2020 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
Prospectus 2020 | 205 |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a |
206 | Prospectus 2020 |
credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 207 |
208 | Prospectus 2020 |
Prospectus 2020 | 209 |
210 | Prospectus 2020 |
Prospectus 2020 | 211 |
212 | Prospectus 2020 |
Prospectus 2020 | 213 |
214 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 215 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
216 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP® – T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Prospectus 2020 | 217 |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio – High Yield Bond Fund, Columbia Variable Portfolio – Income Opportunities Fund, Columbia Variable
Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio –
Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund, CTIVP® – American Century Diversified Bond Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
218 | Prospectus 2020 |
Prospectus 2020 | 219 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
220 | Prospectus 2020 |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 221 |
222 | Prospectus 2020 |
Prospectus 2020 | 223 |
224 | Prospectus 2020 |
Prospectus 2020 | 225 |
226 | Prospectus 2020 |
Prospectus 2020 | 227 |
228 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 229 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
230 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP® – T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Prospectus 2020 | 231 |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio – High Yield Bond Fund, Columbia Variable Portfolio – Income Opportunities Fund, Columbia Variable
Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio –
Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund, CTIVP® – American Century Diversified Bond Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
232 | Prospectus 2020 |
Prospectus 2020 | 233 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
234 | Prospectus 2020 |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 235 |
236 | Prospectus 2020 |
Prospectus 2020 | 237 |
238 | Prospectus 2020 |
Prospectus 2020 | 239 |
240 | Prospectus 2020 |
Prospectus 2020 | 241 |
242 | Prospectus 2020 |
■ | derivative transactions, including forward contracts, futures, options and swaps; |
■ | direct investments in exchange-traded funds (ETFs); and |
■ | direct investments in fixed-income or debt instruments (such as investment grade corporate bonds, high yield (i.e., junk) instruments, U.S. Government bonds and notes, Treasury inflation-protected securities (TIPS), mortgage- and other asset-backed securities, and mortgage dollar rolls, each with varying interest rates, terms, durations and credit exposures). |
Prospectus 2020 | 243 |
■ | Selects and determines allocations to the Underlying Funds (referred to as the Strategic Allocation); and |
■ | Invests in and determines allocations to the Tactical Assets to adjust desired asset class exposures (referred to as the Tactical Allocation). |
244 | Prospectus 2020 |
Equity Underlying Funds | Columbia Variable Portfolio – Contrarian Core Fund, Columbia Variable Portfolio – Disciplined Core Fund, Columbia Variable Portfolio – Dividend Opportunity Fund, Columbia Variable Portfolio – Large Cap Growth Fund, Columbia Variable Portfolio – Large Cap Index Fund, Columbia Variable Portfolio – Mid Cap Growth Fund, Columbia Variable Portfolio – Select Large Cap Equity Fund, Columbia Variable Portfolio – Select Large Cap Value Fund, Columbia Variable Portfolio – Select Mid Cap Value Fund, Columbia Variable Portfolio – Select Small Cap Value Fund, CTIVP® – CenterSquare Real Estate Fund, CTIVP® – Loomis Sayles Growth Fund, CTIVP® – Los Angeles Capital Large Cap Growth Fund, CTIVP® – MFS® Value Fund, CTIVP® – Morgan Stanley Advantage Fund, CTIVP® – T. Rowe Price Large Cap Value Fund, CTIVP® – Victory Sycamore Established Value Fund, CTIVP® – Westfield Mid Cap Growth Fund, Variable Portfolio – Partners Core Equity Fund, Variable Portfolio – Partners Small Cap Growth Fund and Variable Portfolio – Partners Small Cap Value Fund. |
Prospectus 2020 | 245 |
Fixed-Income Underlying Funds |
Columbia Variable Portfolio – High Yield Bond Fund, Columbia Variable Portfolio – Income Opportunities Fund, Columbia Variable
Portfolio – Intermediate Bond Fund, Columbia Variable Portfolio – Limited Duration Credit Fund, Columbia Variable Portfolio – Long Government/Credit Bond Fund, Columbia Variable Portfolio –
Strategic Income Fund, Columbia Variable Portfolio – U.S. Government Mortgage Fund, CTIVP® – American Century Diversified Bond Fund, CTIVP® – TCW Core Plus Bond Fund, CTIVP® –– Wells Fargo Short Duration Government Fund and Variable Portfolio – Partners Core Bond Fund.
|
246 | Prospectus 2020 |
Prospectus 2020 | 247 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
248 | Prospectus 2020 |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
Prospectus 2020 | 249 |
250 | Prospectus 2020 |
Prospectus 2020 | 251 |
252 | Prospectus 2020 |
Prospectus 2020 | 253 |
254 | Prospectus 2020 |
Prospectus 2020 | 255 |
256 | Prospectus 2020 |
Prospectus 2020 | 257 |
258 | Prospectus 2020 |
Prospectus 2020 | 259 |
260 | Prospectus 2020 |
Class 1 | Class 2 | |
Variable Portfolio – Managed Risk Fund | 0.80% | 1.05% |
Variable Portfolio – Managed Risk U.S. Fund | 0.80% | 1.05% |
Variable Portfolio – Managed Volatility Conservative Fund | 0.80% | 1.05% |
Variable Portfolio – Managed Volatility Conservative Growth Fund | 0.80% | 1.05% |
Variable Portfolio – Managed Volatility Growth Fund | 0.80% | 1.05% |
Variable Portfolio – Managed Volatility Moderate Growth Fund | 0.80% | 1.05% |
Variable Portfolio – U.S. Flexible Conservative Growth Fund | 0.80% | 1.05% |
Variable Portfolio – U.S. Flexible Growth Fund | 0.80% | 1.05% |
Variable Portfolio – U.S. Flexible Moderate Growth Fund | 0.80% | 1.05% |
Prospectus 2020 | 261 |
Management fee for the fiscal year ended December 31, 2019 | |
Variable Portfolio – Managed Risk Fund | 0.13% |
Variable Portfolio – Managed Risk U.S. Fund | 0.12% |
Variable Portfolio – Managed Volatility Conservative Fund | 0.23% |
Variable Portfolio – Managed Volatility Conservative Growth Fund | 0.22% |
Variable Portfolio – Managed Volatility Growth Fund | 0.18% |
Variable Portfolio – Managed Volatility Moderate Growth Fund | 0.17% |
Variable Portfolio – U.S. Flexible Conservative Growth Fund | 0.23% |
Variable Portfolio – U.S. Flexible Growth Fund | 0.22% |
Variable Portfolio – U.S. Flexible Moderate Growth Fund | 0.22% |
262 | Prospectus 2020 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | ||
For
Variable Portfolio (VP) – Managed Risk Fund and VP – Managed Risk U.S. Fund |
For
VP – Managed Volatility Conservative Fund, VP – Managed Volatility Conservative Growth Fund, VP - Managed Volatility Growth Fund and VP – Managed Volatility Moderate Growth Fund |
For VP – U.S. Flexible
Conservative Growth Fund, VP – U.S. Flexible Growth Fund and VP – U.S. Flexible Moderate Growth Fund |
|||
Brian Virginia | Senior Portfolio Manager and Head of Insurance Investments |
Lead Portfolio
Manager |
2017 | 2014 | 2016 |
Anwiti Bahuguna, Ph.D. | Senior Portfolio Manager and Head of Multi Asset Strategy |
Portfolio
Manager |
2017 | 2015 | 2016 |
David Weiss, CFA | Vice President, Head of Sub-Advisory Management |
Portfolio
Manager |
2017 | 2016 | 2016 |
Joshua Kutin, CFA | Senior Portfolio Manager and Head of North America Asset Allocation |
Portfolio
Manager |
2018 | 2018 | 2018 |
Prospectus 2020 | 263 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
264 | Prospectus 2020 |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
Prospectus 2020 | 265 |
Class 1 Shares | Class 2 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and in variable life insurance policies (collectively, Contracts) or other eligible investors authorized by the Distributor. | |
Investment Limits | none | none |
Conversion Features | none | none |
Front-End Sales Charges | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% |
266 | Prospectus 2020 |
Prospectus 2020 | 267 |
268 | Prospectus 2020 |
Prospectus 2020 | 269 |
270 | Prospectus 2020 |
Prospectus 2020 | 271 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; and |
■ | increased brokerage and administrative costs. |
272 | Prospectus 2020 |
Prospectus 2020 | 273 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. |
274 | Prospectus 2020 |
Prospectus 2020 | 275 |
Prospectus 2020 | 277 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $10.48 | 0.15 | 0.81 | 0.96 |
Class 2 | ||||
Year Ended 12/31/2019 | $9.84 | 0.12 | 1.46 | 1.58 |
Year Ended 12/31/2018 | $10.39 | 0.09 | (0.64) | (0.55) |
Year Ended 12/31/2017(e) | $10.00 | (0.00) (f) | 0.39 | 0.39 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
(e) | The Fund commenced operations on September 12, 2017. Per share data and total return reflect activity from that date. |
(f) | Rounds to zero. |
278 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $11.44 | 9.16% | 0.25% (d) | 0.25% (d) | 1.57% (d) | 37% | $3 |
Class 2 | |||||||
Year Ended 12/31/2019 | $11.42 | 16.06% | 0.51% | 0.51% | 1.12% | 37% | $186,750 |
Year Ended 12/31/2018 | $9.84 | (5.29%) | 0.61% | 0.55% | 0.85% | 47% | $97,370 |
Year Ended 12/31/2017(e) | $10.39 | 3.90% | 1.17% (d) | 0.49% (d) | (0.01%) (d) | 75% | $17,803 |
Prospectus 2020 | 279 |
Prospectus 2020 | 281 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $10.75 | 0.10 | 1.12 | 1.22 |
Class 2 | ||||
Year Ended 12/31/2019 | $10.10 | 0.07 | 1.78 | 1.85 |
Year Ended 12/31/2018 | $10.47 | 0.04 | (0.41) | (0.37) |
Year Ended 12/31/2017(e) | $10.00 | (0.01) | 0.48 | 0.47 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
(e) | The Fund commenced operations on September 12, 2017. Per share data and total return reflect activity from that date. |
282 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $11.97 | 11.35% | 0.25% (d) | 0.25% (d) | 1.02% (d) | 24% | $3 |
Class 2 | |||||||
Year Ended 12/31/2019 | $11.95 | 18.32% | 0.52% | 0.52% | 0.61% | 24% | $186,201 |
Year Ended 12/31/2018 | $10.10 | (3.53%) | 0.67% | 0.58% | 0.41% | 45% | $80,119 |
Year Ended 12/31/2017(e) | $10.47 | 4.70% | 1.19% (d) | 0.52% (d) | (0.26%) (d) | 109% | $12,190 |
Prospectus 2020 | 283 |
Prospectus 2020 | 285 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $11.70 | 0.17 | 0.83 | 1.00 |
Class 2 | ||||
Year Ended 12/31/2019 | $11.33 | 0.23 | 1.12 | 1.35 |
Year Ended 12/31/2018 | $11.63 | 0.17 | (0.47) | (0.30) |
Year Ended 12/31/2017 | $10.78 | 0.13 | 0.72 | 0.85 |
Year Ended 12/31/2016 | $10.46 | 0.09 | 0.23 | 0.32 |
Year Ended 12/31/2015 | $10.58 | 0.10 | (0.22) | (0.12) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
286 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $12.70 | 8.55% | 0.31% (d) | 0.31% (d) | 1.57% (d) | 139% | $53 |
Class 2 | |||||||
Year Ended 12/31/2019 | $12.68 | 11.91% | 0.57% | 0.57% | 1.90% | 139% | $572,701 |
Year Ended 12/31/2018 | $11.33 | (2.58%) | 0.57% | 0.57% | 1.45% | 119% | $426,294 |
Year Ended 12/31/2017 | $11.63 | 7.88% | 0.55% | 0.55% | 1.17% | 103% | $462,907 |
Year Ended 12/31/2016 | $10.78 | 3.06% | 0.53% | 0.53% | 0.86% | 106% | $444,792 |
Year Ended 12/31/2015 | $10.46 | (1.13%) | 0.56% | 0.56% | 0.98% | 142% | $241,975 |
Prospectus 2020 | 287 |
Prospectus 2020 | 289 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $12.36 | 0.16 | 0.95 | 1.11 |
Class 2 | ||||
Year Ended 12/31/2019 | $11.79 | 0.20 | 1.45 | 1.65 |
Year Ended 12/31/2018 | $12.32 | 0.15 | (0.68) | (0.53) |
Year Ended 12/31/2017 | $11.08 | 0.11 | 1.13 | 1.24 |
Year Ended 12/31/2016 | $10.74 | 0.07 | 0.27 | 0.34 |
Year Ended 12/31/2015 | $10.94 | 0.09 | (0.29) | (0.20) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
290 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $13.47 | 8.98% | 0.29% (d) | 0.29% (d) | 1.46% (d) | 137% | $207 |
Class 2 | |||||||
Year Ended 12/31/2019 | $13.44 | 14.00% | 0.54% | 0.54% | 1.58% | 137% | $1,520,725 |
Year Ended 12/31/2018 | $11.79 | (4.30%) | 0.54% | 0.54% | 1.21% | 101% | $1,300,981 |
Year Ended 12/31/2017 | $12.32 | 11.19% | 0.53% | 0.53% | 0.95% | 100% | $1,425,498 |
Year Ended 12/31/2016 | $11.08 | 3.17% | 0.51% | 0.51% | 0.64% | 108% | $1,358,964 |
Year Ended 12/31/2015 | $10.74 | (1.83%) | 0.52% | 0.52% | 0.83% | 118% | $936,541 |
Prospectus 2020 | 291 |
Prospectus 2020 | 293 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $13.62 | 0.11 | 1.23 | 1.34 |
Class 2 | ||||
Year Ended 12/31/2019 | $12.65 | 0.13 | 2.18 | 2.31 |
Year Ended 12/31/2018 | $13.71 | 0.09 | (1.15) | (1.06) |
Year Ended 12/31/2017 | $11.67 | 0.05 | 1.99 | 2.04 |
Year Ended 12/31/2016 | $11.29 | 0.04 | 0.34 | 0.38 |
Year Ended 12/31/2015 | $11.68 | 0.03 | (0.42) | (0.39) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
294 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $14.96 | 9.84% | 0.25% (d) | 0.25% (d) | 0.88% (d) | 128% | $1,985 |
Class 2 | |||||||
Year Ended 12/31/2019 | $14.96 | 18.26% | 0.49% | 0.49% | 0.91% | 128% | $11,450,160 |
Year Ended 12/31/2018 | $12.65 | (7.73%) | 0.49% | 0.49% | 0.65% | 74% | $9,820,308 |
Year Ended 12/31/2017 | $13.71 | 17.48% | 0.48% | 0.48% | 0.42% | 83% | $10,121,668 |
Year Ended 12/31/2016 | $11.67 | 3.37% | 0.47% | 0.47% | 0.37% | 91% | $8,232,846 |
Year Ended 12/31/2015 | $11.29 | (3.34%) | 0.48% | 0.48% | 0.29% | 74% | $7,441,534 |
Prospectus 2020 | 295 |
Prospectus 2020 | 297 |
Net asset value,
beginning of period |
Net
investment income |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $14.19 | 0.13 | 1.21 | 1.34 |
Class 2 | ||||
Year Ended 12/31/2019 | $13.36 | 0.18 | 1.98 | 2.16 |
Year Ended 12/31/2018 | $14.19 | 0.13 | (0.96) | (0.83) |
Year Ended 12/31/2017 | $12.41 | 0.09 | 1.69 | 1.78 |
Year Ended 12/31/2016 | $12.00 | 0.07 | 0.34 | 0.41 |
Year Ended 12/31/2015 | $12.31 | 0.08 | (0.39) | (0.31) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
298 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $15.53 | 9.44% | 0.24% (d) | 0.24% (d) | 1.01% (d) | 138% | $1,093 |
Class 2 | |||||||
Year Ended 12/31/2019 | $15.52 | 16.17% | 0.49% | 0.49% | 1.25% | 138% | $15,229,993 |
Year Ended 12/31/2018 | $13.36 | (5.85%) | 0.49% | 0.49% | 0.90% | 92% | $13,743,943 |
Year Ended 12/31/2017 | $14.19 | 14.34% | 0.47% | 0.47% | 0.69% | 98% | $14,678,387 |
Year Ended 12/31/2016 | $12.41 | 3.42% | 0.46% | 0.46% | 0.57% | 112% | $12,877,836 |
Year Ended 12/31/2015 | $12.00 | (2.52%) | 0.47% | 0.47% | 0.64% | 119% | $11,278,182 |
Prospectus 2020 | 299 |
Prospectus 2020 | 301 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $11.47 | 0.20 | 0.96 | 1.16 |
Class 2 | ||||
Year Ended 12/31/2019 | $10.97 | 0.17 | 1.46 | 1.63 |
Year Ended 12/31/2018 | $11.25 | 0.11 | (0.39) | (0.28) |
Year Ended 12/31/2017 | $10.07 | 0.09 | 1.09 | 1.18 |
Year Ended 12/31/2016(e) | $10.00 | (0.02) | 0.09 | 0.07 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
(e) | The Fund commenced operations on November 2, 2016. Per share data and total return reflect activity from that date. |
302 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $12.63 | 10.11% | 0.32% (d) | 0.32% (d) | 1.98% (d) | 156% | $3 |
Class 2 | |||||||
Year Ended 12/31/2019 | $12.60 | 14.86% | 0.59% | 0.59% | 1.42% | 156% | $288,927 |
Year Ended 12/31/2018 | $10.97 | (2.49%) | 0.65% | 0.65% | 0.99% | 51% | $139,061 |
Year Ended 12/31/2017 | $11.25 | 11.72% | 0.74% | 0.67% | 0.80% | 49% | $82,636 |
Year Ended 12/31/2016(e) | $10.07 | 0.70% | 1.08% (d) | 0.66% (d) | (0.28%) (d) | 10% | $18,272 |
Prospectus 2020 | 303 |
Prospectus 2020 | 305 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $12.62 | 0.06 | 1.51 | 1.57 |
Class 2 | ||||
Year Ended 12/31/2019 | $11.78 | 0.08 | 2.30 | 2.38 |
Year Ended 12/31/2018 | $12.26 | 0.05 | (0.53) | (0.48) |
Year Ended 12/31/2017 | $10.35 | 0.02 | 1.89 | 1.91 |
Year Ended 12/31/2016(e) | $10.00 | (0.01) | 0.36 | 0.35 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
(e) | The Fund commenced operations on November 2, 2016. Per share data and total return reflect activity from that date. |
306 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $14.19 | 12.44% | 0.30% (d) | 0.30% (d) | 0.52% (d) | 132% | $132 |
Class 2 | |||||||
Year Ended 12/31/2019 | $14.16 | 20.20% | 0.54% | 0.54% | 0.57% | 132% | $3,032,993 |
Year Ended 12/31/2018 | $11.78 | (3.92%) | 0.55% | 0.55% | 0.38% | 44% | $1,705,527 |
Year Ended 12/31/2017 | $12.26 | 18.45% | 0.55% | 0.55% | 0.17% | 9% | $998,296 |
Year Ended 12/31/2016(e) | $10.35 | 3.50% | 0.63% (d) | 0.63% (d) | (0.26%) (d) | 12% | $166,632 |
Prospectus 2020 | 307 |
Prospectus 2020 | 309 |
Net asset value,
beginning of period |
Net
investment income (loss) |
Net
realized and unrealized gain (loss) |
Total from
investment operations |
|
Class 1 | ||||
Year Ended 12/31/2019(c) | $12.05 | 0.20 | 1.16 | 1.36 |
Class 2 | ||||
Year Ended 12/31/2019 | $11.38 | 0.13 | 1.87 | 2.00 |
Year Ended 12/31/2018 | $11.76 | 0.09 | (0.47) | (0.38) |
Year Ended 12/31/2017 | $10.21 | 0.06 | 1.49 | 1.55 |
Year Ended 12/31/2016(e) | $10.00 | (0.01) | 0.22 | 0.21 |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Class 1 shares commenced operations on February 20, 2019. Per share data and total return reflect activity from that date. |
(d) | Annualized. |
(e) | The Fund commenced operations on November 2, 2016. Per share data and total return reflect activity from that date. |
310 | Prospectus 2020 |
Net
asset value, end of period |
Total
return |
Total gross
expense ratio to average net assets(a) |
Total net
expense ratio to average net assets(a), (b) |
Net investment
income (loss) ratio to average net assets |
Portfolio
turnover |
Net
assets, end of period (000's) |
|
Class 1 | |||||||
Year Ended 12/31/2019(c) | $13.41 | 11.29% | 0.30% (d) | 0.30% (d) | 1.84% (d) | 125% | $299 |
Class 2 | |||||||
Year Ended 12/31/2019 | $13.38 | 17.57% | 0.55% | 0.55% | 1.05% | 125% | $1,832,787 |
Year Ended 12/31/2018 | $11.38 | (3.23%) | 0.56% | 0.56% | 0.74% | 42% | $1,142,028 |
Year Ended 12/31/2017 | $11.76 | 15.18% | 0.56% | 0.56% | 0.56% | 9% | $715,814 |
Year Ended 12/31/2016(e) | $10.21 | 2.10% | 0.75% (d) | 0.64% (d) | (0.16%) (d) | 16% | $89,784 |
Prospectus 2020 | 311 |
A-1 | Prospectus 2020 |
Prospectus 2020 | A-2 |
A-3 | Prospectus 2020 |
Prospectus 2020 | A-4 |
A-5 | Prospectus 2020 |
Prospectus 2020 | A-6 |
A-7 | Prospectus 2020 |
Prospectus 2020 | A-8 |
A-9 | Prospectus 2020 |
Prospectus 2020 | A-10 |
A-11 | Prospectus 2020 |
■ | Buys securities determined to present minimal credit risk by Columbia Management Investment Advisers, LLC (the Investment Manager). |
■ | Limits its U.S. dollar-weighted average portfolio maturity to 60 days or less and its U.S. dollar-weighted average life to 120 days or less. |
■ | Buys obligations with remaining maturities of 397 days or less (as maturity is calculated by SEC rules governing the operation of money market funds). |
■ | Buys only obligations that are denominated in U.S. dollars. |
Prospectus 2020 | A-12 |
A-13 | Prospectus 2020 |
Prospectus 2020 | A-14 |
A-15 | Prospectus 2020 |
Prospectus 2020 | A-16 |
A-17 | Prospectus 2020 |
Prospectus 2020 | A-18 |
A-19 | Prospectus 2020 |
Prospectus 2020 | B-1 |
B-2 | Prospectus 2020 |
Prospectus 2020 | B-3 |
B-4 | Prospectus 2020 |
Prospectus 2020 | B-5 |
B-6 | Prospectus 2020 |
Prospectus 2020 | B-7 |
B-8 | Prospectus 2020 |
Prospectus 2020 | B-9 |
B-10 | Prospectus 2020 |
Prospectus 2020 | B-11 |
B-12 | Prospectus 2020 |
Prospectus 2020 | B-13 |
B-14 | Prospectus 2020 |
Prospectus 2020 | B-15 |
B-16 | Prospectus 2020 |
Funds | Trust |
Investment company
registration number |
Variable Portfolio – Managed Risk Fund | Columbia Funds Variable Insurance Trust | 811-05199 |
Variable Portfolio – Managed Risk U.S. Fund | ||
Variable Portfolio – Managed Volatility Conservative Fund | ||
Variable Portfolio – Managed Volatility Conservative Growth Fund | ||
Variable Portfolio – Managed Volatility Growth Fund | ||
Variable Portfolio – U.S. Flexible Conservative Growth Fund | ||
Variable Portfolio – U.S. Flexible Growth Fund | ||
Variable Portfolio – U.S. Flexible Moderate Growth Fund | ||
Variable Portfolio – Managed Volatility Moderate Growth Fund | Columbia Funds Variable Series Trust II | 811-22127 |
Columbia Funds Variable Series Trust II |
Columbia Variable Portfolio – Balanced Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Commodity Strategy Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Core Equity Fund*: single class of shares |
Columbia Variable Portfolio – Disciplined Core Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Dividend Opportunity Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Emerging Markets Bond Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Emerging Markets Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Global Strategic Income Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Government Money Market Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – High Yield Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Income Opportunities Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Intermediate Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Large Cap Growth Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Large Cap Index Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Limited Duration Credit Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Mid Cap Growth Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Overseas Core Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Large Cap Equity Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Select Large Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Mid Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Small Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Seligman Global Technology Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – U.S. Government Mortgage Fund: Class 1, Class 2 & Class 3 |
CTIVP® – American Century Diversified Bond Fund: Class 1 & Class 2 |
CTIVP® – BlackRock Global Inflation-Protected Securities Fund: Class 1, Class 2 & Class 3 |
CTIVP® – CenterSquare Real Estate Fund: Class 1 & Class 2 |
CTIVP® – Loomis Sayles Growth Fund: Class 1 & Class 2 |
CTIVP® – Los Angeles Capital Large Cap Growth Fund: Class 1 & Class 2 |
CTIVP® – MFS® Value Fund: Class 1 & Class 2 |
CTIVP® – Morgan Stanley Advantage Fund: Class 1 & Class 2 |
CTIVP® – T. Rowe Price Large Cap Value Fund: Class 1 & Class 2 |
CTIVP® – TCW Core Plus Bond Fund: Class 1 & Class 2 |
CTIVP® – Victory Sycamore Established Value Fund: Class 1, Class 2 & Class 3 |
CTIVP® – Wells Fargo Short Duration Government Fund: Class 1 & Class 2 |
CTIVP® – Westfield Mid Cap Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Aggressive Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Conservative Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Managed Volatility Moderate Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Moderate Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Moderately Aggressive Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Moderately Conservative Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Partners International Core Equity Fund: Class 1 & Class 2 |
Variable Portfolio – Partners International Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Partners International Value Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Core Bond Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Core Equity Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – Partners Small Cap Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Small Cap Value Fund: Class 1, Class 2 & Class 3 |
* | This Fund is closed to new investors. |
|
2 |
|
7 |
|
10 |
|
18 |
|
18 |
|
54 |
|
83 |
|
84 |
|
84 |
|
86 |
|
86 |
|
110 |
|
127 |
|
139 |
|
139 |
|
139 |
|
141 |
|
142 |
|
144 |
|
148 |
|
149 |
|
150 |
|
152 |
|
152 |
|
161 |
|
166 |
|
166 |
|
169 |
|
171 |
|
173 |
|
177 |
|
177 |
|
177 |
|
178 |
|
185 |
|
186 |
|
188 |
|
188 |
|
189 |
|
191 |
|
191 |
|
192 |
|
194 |
|
204 |
|
226 |
|
A-1 |
|
B-1 |
Statement of Additional Information – May 1, 2020 | 1 |
■ | the organization of the Trust; |
■ | the Funds' investments; |
■ | the Funds' investment adviser, investment subadviser(s) (if any) and other service providers, including roles and relationships of Ameriprise Financial and its affiliates, and conflicts of interest; |
■ | the governance of the Funds; |
■ | the Funds' brokerage practices; |
■ | the share classes offered by the Funds; |
■ | the purchase, redemption and pricing of Fund shares; and |
■ | the application of U.S. federal income tax laws. |
1933 Act | Securities Act of 1933, as amended |
1934 Act | Securities Exchange Act of 1934, as amended |
1940 Act | Investment Company Act of 1940, as amended |
American Century | American Century Investment Management, Inc. |
Ameriprise Financial | Ameriprise Financial, Inc. |
AQR | AQR Capital Management, LLC |
BlackRock | BlackRock Financial Management, Inc. |
BIL | BlackRock International Limited, an affiliate of BlackRock |
BMO | BMO Asset Management Corp. |
Board | The Trust’s Board of Trustees |
Statement of Additional Information – May 1, 2020 | 2 |
Business Day | Any day on which the NYSE is open for business. A business day typically ends at the close of regular trading on the NYSE, usually at 4:00 p.m. Eastern time. If the NYSE is scheduled to close early, the business day will be considered to end as of the time of the NYSE’s scheduled close. The Fund will not treat an intraday unscheduled disruption in NYSE trading or an intraday unscheduled closing as a close of regular trading on the NYSE for these purposes and will price its shares as of the regularly scheduled closing time for that day (typically, 4:00 p.m. Eastern time). Notwithstanding the foregoing, the NAV of Fund shares may be determined at such other time or times (in addition to or in lieu of the time set forth above) as the Fund’s Board may approve or ratify. On holidays and other days when the NYSE is closed, the Fund's NAV is not calculated and the Fund does not accept buy or sell orders. However, the value of the Fund's assets may still be affected on such days to the extent that the Fund holds foreign securities that trade on days that foreign securities markets are open. |
CEA | Commodity Exchange Act |
CenterSquare | CenterSquare Investment Management LLC |
CFTC | The United States Commodity Futures Trading Commission |
CFVST II | Columbia Funds Variable Series Trust II |
CMOs | Collateralized mortgage obligations |
Code | Internal Revenue Code of 1986, as amended |
Codes of Ethics | The codes of ethics adopted by the Funds, the Investment Manager, Columbia Management Investment Distributors, Inc. and/or any sub-adviser, as applicable, pursuant to Rule 17j-1 under the 1940 Act |
Columbia Funds or Columbia Funds Complex | The fund complex, including the Funds, that is comprised of the registered investment companies, including traditional mutual funds, closed-end funds, and ETFs, advised by the Investment Manager or its affiliates |
Columbia Management | Columbia Management Investment Advisers, LLC |
Columbia WAM | Columbia Wanger Asset Management, LLC |
Custodian | JPMorgan Chase Bank, N.A. |
DBRS | DBRS Morningstar |
DFA | Dimensional Fund Advisors LP |
Distribution Agreement | The Distribution Agreement between the Trust, on behalf of its Funds, and the Distributor |
Distribution Plan(s) | One or more of the plans adopted by the Board pursuant to Rule 12b-1 under the 1940 Act for the distribution of the Funds’ shares |
Distributor | Columbia Management Investment Distributors, Inc. |
DST | DST Asset Manager Solutions, Inc. |
FDIC | Federal Deposit Insurance Corporation |
FHLMC | The Federal Home Loan Mortgage Corporation |
Fitch | Fitch Ratings, Inc. |
FNMA | Federal National Mortgage Association |
The Fund(s) or a Fund | One or more of the open-end management investment companies listed on the front cover of this SAI |
GNMA | Government National Mortgage Association |
Independent Trustees | The Trustees of the Board who are not “interested persons” (as defined in the 1940 Act) of the Funds |
Interested Trustee | A Trustee of the Board who is currently deemed to be an “interested person” (as defined in the 1940 Act) of the Funds |
Investment Manager | Columbia Management Investment Advisers, LLC |
IRS | United States Internal Revenue Service |
Statement of Additional Information – May 1, 2020 | 3 |
Jacobs Levy | Jacobs Levy Equity Management, Inc. |
Jennison | Jennison Associates LLC |
JPMIM | J.P. Morgan Investment Management Inc. |
JPMorgan | JPMorgan Chase Bank, N.A., the Funds' custodian |
KBRA | Kroll Bond Rating Agency |
LIBOR | London Interbank Offered Rate* |
Loomis Sayles | Loomis, Sayles & Company, L.P. |
Los Angeles Capital | Los Angeles Capital Management and Equity Research, Inc. |
MFS | Massachusetts Financial Services Company |
Management Agreement | The Management Agreements, as amended, if applicable, between the Trust, on behalf of the Funds, and the Investment Manager |
Moody’s | Moody’s Investors Service, Inc. |
MSIM | Morgan Stanley Investment Management Inc. |
NASDAQ | National Association of Securities Dealers Automated Quotations system |
Nations Funds | The Funds within the Columbia Funds Complex that historically bore the Nations brand |
NAV | Net asset value per share of a Fund |
NRSRO | Nationally recognized statistical ratings organization (such as, for example, Moody’s, Fitch or S&P) |
NSCC | National Securities Clearing Corporation |
NYSE | New York Stock Exchange |
Nuveen Asset Management | Nuveen Asset Management, LLC |
Oppenheimer | OppenheimerFunds Inc. |
Participating Insurance Companies | Life insurance companies that issue the variable annuity contracts or variable life insurance policies through separate accounts for which the Funds serve as underlying investment vehicles |
Pyramis | FIAM LLC (doing business as Pyramis Global Advisors) |
PwC | PricewaterhouseCoopers LLP |
REIT | Real estate investment trust |
REMIC | Real estate mortgage investment conduit |
RIC | A “regulated investment company,” as such term is used in the Code |
RiverSource Funds | The Funds within the Columbia Funds Complex that historically bore the RiverSource brand and includes series of CFVST II |
S&P | Standard & Poor’s, a division of The McGraw-Hill Companies, Inc. (“Standard & Poor’s” and “S&P” are trademarks of The McGraw-Hill Companies, Inc. and have been licensed for use by the Investment Manager. The Columbia Funds are not sponsored, endorsed, sold or promoted by Standard & Poor’s and Standard & Poor’s makes no representation regarding the advisability of investing in the Columbia Funds) |
SAI | This Statement of Additional Information, as amended and supplemented from time-to-time |
SBH | Segall Bryant & Hamill, LLC |
Scout | Scout Investments, Inc. |
SEC | United States Securities and Exchange Commission |
Shareholder Services Agreement | The Shareholder Services Agreement between the Trust, on behalf of its Funds, and the Transfer Agent |
Shares | Shares of a Fund |
Subadvisory Agreement | The Subadvisory Agreement among the Trust on behalf of the Fund(s), the Investment Manager and a Fund’s investment subadviser(s), as the context may require |
Statement of Additional Information – May 1, 2020 | 4 |
Subsidiary | One or more wholly-owned subsidiaries of a Fund |
T. Rowe Price | T. Rowe Price Associates, Inc. |
TCW | TCW Investment Management Company LLC |
Threadneedle | Threadneedle International Limited |
Transfer Agent | Columbia Management Investment Services Corp. |
Treasury Regulations | Regulations promulgated under the Code by the United States Treasury Department |
Trustee(s) | One or more members of the Board |
Trust | Columbia Funds Variable Series Trust II, the registered investment company in the Columbia Funds Complex to which this SAI relates |
VA Contracts | Variable annuity contracts |
Victory Capital | Victory Capital Management Inc. |
VLI Policy(ies) | Variable life insurance policy(ies) |
VP – Managed Volatility Funds | Any variable portfolio fund that includes the words “Managed Risk,” “Managed Volatility,” or “U.S. Flexible” as part of the Fund’s name |
VP – Portfolio Navigator Funds | VP – Aggressive Portfolio, VP – Conservative Portfolio, VP – Moderate Portfolio, VP – Moderately Aggressive Portfolio and VP – Moderately Conservative Portfolio |
WellsCap | Wells Capital Management Incorporated |
Westfield | Westfield Capital Management Company, L.P. |
William Blair | William Blair Investment Management, LLC |
Winslow Capital | Winslow Capital Management LLC |
* | On July 27, 2017, the head of the United Kingdom’s Financial Conduct Authority announced a desire to phase out the use of LIBOR by the end of 2021. There remains uncertainty regarding the future utilization of LIBOR and the nature of any replacement rate. |
Fund Name: | Referred to as: | |
Columbia Variable Portfolio – Balanced Fund | VP – Balanced Fund | |
Columbia Variable Portfolio – Commodity Strategy Fund | VP – Commodity Strategy Fund | |
Columbia Variable Portfolio – Core Equity Fund | VP – Core Equity Fund | |
Columbia Variable Portfolio – Disciplined Core Fund | VP – Disciplined Core Fund | |
Columbia Variable Portfolio – Dividend Opportunity Fund | VP – Dividend Opportunity Fund | |
Columbia Variable Portfolio – Emerging Markets Bond Fund | VP – Emerging Markets Bond Fund | |
Columbia Variable Portfolio – Emerging Markets Fund | VP – Emerging Markets Fund | |
Columbia Variable Portfolio – Global Strategic Income Fund | VP – Global Strategic Income Fund | |
Columbia Variable Portfolio – Government Money Market Fund | VP – Government Money Market Fund | |
Columbia Variable Portfolio – High Yield Bond Fund | VP – High Yield Bond Fund | |
Columbia Variable Portfolio – Income Opportunities Fund | VP – Income Opportunities Fund | |
Columbia Variable Portfolio – Intermediate Bond Fund | VP – Intermediate Bond Fund | |
Columbia Variable Portfolio – Large Cap Growth Fund | VP – Large Cap Growth Fund | |
Columbia Variable Portfolio – Large Cap Index Fund | VP – Large Cap Index Fund | |
Columbia Variable Portfolio – Limited Duration Credit Fund | VP – Limited Duration Credit Fund | |
Columbia Variable Portfolio – Mid Cap Growth Fund | VP – Mid Cap Growth Fund | |
Columbia Variable Portfolio – Overseas Core Fund | VP – Overseas Core Fund | |
Columbia Variable Portfolio – Select Large Cap Equity Fund | VP – Select Large Cap Equity Fund | |
Columbia Variable Portfolio – Select Large Cap Value Fund | VP – Select Large Cap Value Fund | |
Columbia Variable Portfolio – Select Mid Cap Value Fund | VP – Select Mid Cap Value Fund | |
Columbia Variable Portfolio – Select Small Cap Value Fund | VP – Select Small Cap Value Fund |
Statement of Additional Information – May 1, 2020 | 5 |
Fund Name: | Referred to as: | |
Columbia Variable Portfolio – Seligman Global Technology Fund | VP – Seligman Global Technology Fund | |
Columbia Variable Portfolio – U.S. Government Mortgage Fund | VP – U.S. Government Mortgage Fund | |
CTIVP® – American Century Diversified Bond Fund | VP – American Century Diversified Bond Fund | |
CTIVP® – BlackRock Global Inflation-Protected Securities Fund |
VP – BlackRock Global Inflation-Protected
Securities Fund |
|
CTIVP® – CenterSquare Real Estate Fund | VP – CenterSquare Real Estate Fund | |
CTIVP® – Loomis Sayles Growth Fund | VP – Loomis Sayles Growth Fund | |
CTIVP® – Los Angeles Large Cap Growth Fund | VP – Los Angeles Large Cap Growth Fund | |
CTIVP® – MFS® Value Fund | VP – MFS Value Fund | |
CTIVP® – Morgan Stanley Advantage Fund | VP – Morgan Stanley Advantage Fund | |
CTIVP® – T. Rowe Price Large Cap Value Fund | VP – T. Rowe Price Large Cap Value Fund | |
CTIVP® – TCW Core Plus Bond Fund | VP – TCW Core Plus Bond Fund | |
CTIVP® – Victory Sycamore Established Value Fund | VP – Victory Sycamore Established Value Fund | |
CTIVP® – Wells Fargo Short Duration Government Fund | VP – Wells Fargo Short Duration Government Fund | |
CTIVP® – Westfield Mid Cap Growth Fund | VP – Westfield Mid Cap Growth Fund | |
Variable Portfolio – Aggressive Portfolio | VP – Aggressive Portfolio | |
Variable Portfolio – Conservative Portfolio | VP – Conservative Portfolio | |
Variable Portfolio – Managed Volatility Moderate Growth Fund | VP – MV Moderate Growth Fund | |
Variable Portfolio – Moderate Portfolio | VP – Moderate Portfolio | |
Variable Portfolio – Moderately Aggressive Portfolio | VP – Moderately Aggressive Portfolio | |
Variable Portfolio – Moderately Conservative Portfolio | VP – Moderately Conservative Portfolio | |
Variable Portfolio – Partners Core Bond Fund | VP – Partners Core Bond Fund | |
Variable Portfolio – Partners Core Equity Fund | VP – Partners Core Equity Fund | |
Variable Portfolio – Partners International Core Equity Fund | VP – Partners International Core Equity Fund | |
Variable Portfolio – Partners International Growth Fund | VP – Partners International Growth Fund | |
Variable Portfolio – Partners International Value Fund | VP – Partners International Value Fund | |
Variable Portfolio – Partners Small Cap Growth Fund | VP – Partners Small Cap Growth Fund | |
Variable Portfolio – Partners Small Cap Value Fund | VP – Partners Small Cap Value Fund |
Statement of Additional Information – May 1, 2020 | 6 |
Fund | Date Began Operations* | Diversified** | Fund Investment Category*** |
VP – Aggressive Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – American Century Diversified Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – Balanced Fund | April 30, 1986 | Yes | Flexible |
VP – BlackRock Global Inflation-Protected Securities Fund | September 13, 2004 | No | Fixed Income |
VP – CenterSquare Real Estate Fund | May 7, 2010 | Yes | Equity |
VP – Commodity Strategy Fund | April 30, 2013 | Yes | Equity |
VP – Conservative Portfolio | May 7, 2010 | Yes | Fund-of-funds – Fixed Income |
VP – Core Equity Fund | September 10, 2004 | Yes | Equity |
VP – Disciplined Core Fund | October 13, 1981 | Yes | Equity |
VP – Dividend Opportunity Fund | September 15, 1999 | Yes | Equity |
VP – Emerging Markets Bond Fund | April 30, 2012 | No | Fixed Income |
VP – Emerging Markets Fund | May 1, 2000 | Yes | Equity |
VP – Global Strategic Income Fund | May 1, 1996 | Yes | Fixed Income |
VP – Government Money Market Fund | October 31, 1981 | Yes | Money Market |
VP – High Yield Bond Fund | May 1, 1996 | Yes | Fixed Income |
VP – Income Opportunities Fund | June 1, 2004 | Yes | Fixed Income |
VP – Intermediate Bond Fund | October 13, 1981 | Yes | Fixed Income |
VP – Large Cap Growth Fund | September 15, 1999 | Yes | Equity |
VP – Large Cap Index Fund | May 1, 2000 | Yes | Equity |
VP – Limited Duration Credit Fund | May 7, 2010 | Yes | Fixed Income |
VP – Loomis Sayles Growth Fund | May 7, 2010 | Yes | Equity |
VP – Los Angeles Capital Large Cap Growth Fund | May 7, 2010 | Yes | Equity |
VP – MV Moderate Growth Fund | April 19, 2012 | Yes | Fund-of-funds – Equity |
VP – MFS Value Fund | May 7, 2010 | Yes | Equity |
VP – Mid Cap Growth Fund | May 1, 2001 | Yes | Equity |
VP – Moderate Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – Moderately Aggressive Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – Moderately Conservative Portfolio | May 7, 2010 | Yes | Fund-of-funds – Fixed Income |
VP – Morgan Stanley Advantage Fund | May 7, 2010 | Yes | Equity |
VP – Overseas Core Fund | January 13, 1992 | Yes | Equity |
VP – Partners International Core Equity Fund | May 7, 2010 | Yes | Equity |
Statement of Additional Information – May 1, 2020 | 7 |
Fund | Date Began Operations* | Diversified** | Fund Investment Category*** |
VP – Partners International Growth Fund | May 7, 2010 | Yes | Equity |
VP – Partners International Value Fund | May 7, 2010 | Yes | Equity |
VP – Partners Core Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – Partners Core Equity Fund | May 1, 2006 | Yes | Equity |
VP – Partners Small Cap Growth Fund | May 7, 2010 | Yes | Equity |
VP – Partners Small Cap Value Fund | August 14, 2001 | Yes | Equity |
VP – Select Large Cap Equity Fund | January 4, 2018 | Yes | Equity |
VP – Select Large Cap Value Fund | February 4, 2004 | Yes | Equity |
VP – Select Mid Cap Value Fund | May 2, 2005 | Yes | Equity |
VP – Select Small Cap Value Fund | September 15, 1999 | Yes | Equity |
VP – Seligman Global Technology Fund | May 1, 1996 | No | Equity |
VP – T. Rowe Price Large Cap Value Fund | May 7, 2010 | Yes | Equity |
VP – TCW Core Plus Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – U.S. Government Mortgage Fund | September 15, 1999 | Yes | Fixed Income |
VP – Victory Sycamore Established Value Fund | February 4, 2004 | Yes | Equity |
VP – Wells Fargo Short Duration Government Fund | May 7, 2010 | Yes | Fixed Income |
VP – Westfield Mid Cap Growth Fund | May 7, 2010 | Yes | Equity |
* | Certain Funds reorganized into series of the Trust. The date of operations for these Funds represents the date on which the predecessor funds began operation. |
** | A “diversified” Fund may not, with respect to 75% of its total assets, invest more than 5% of its total assets in securities of any one issuer or purchase more than 10% of the outstanding voting securities of any one issuer, except obligations issued or guaranteed by the U.S. Government, its agencies or instrumentalities and except securities of other investment companies. A “non-diversified” Fund may invest a greater percentage of its total assets in the securities of fewer issuers than a “diversified” fund, which increases the risk that a change in the value of any one investment held by the Fund could affect the overall value of the Fund more than it would affect that of a “diversified” fund holding a greater number of investments. Accordingly, a “non-diversified” Fund’s value will likely be more volatile than the value of a more diversified fund. |
*** | The Fund Investment Category is used as a convenient way to describe Funds in this SAI and should not be deemed a description of the Fund’s principal investment strategies, which are described in the Fund’s prospectus. |
Fund |
Effective Date of
Name Change |
Previous Fund Name |
VP – American Century Diversified Bond Fund | May 1, 2018 | Variable Portfolio – American Century Diversified Bond Fund |
VP – BlackRock Global Inflation-Protected Securities Fund | May 1, 2018 | Variable Portfolio – BlackRock Global Inflation-Protected Securities Fund |
VP – CenterSquare Real Estate Fund |
May 1, 2018
June 1, 2016 |
Variable Portfolio – CenterSquare Real Estate Fund
Variable Portfolio – Morgan Stanley Global Real Estate Fund |
VP – Disciplined Core Fund |
May 1, 2016
|
Columbia Variable Portfolio – Large Core Quantitative Fund |
VP – Global Strategic Income Fund | November 26, 2018 | Columbia Variable Portfolio - Global Bond Fund |
VP – Government Money Market Fund | May 1, 2016 | Columbia Variable Portfolio – Cash Management Fund |
Statement of Additional Information – May 1, 2020 | 8 |
Fund |
Effective Date of
Name Change |
Previous Fund Name |
VP – Loomis Sayles Growth Fund | May 1, 2018 | Variable Portfolio – Loomis Sayles Growth Fund |
VP – Los Angeles Capital Large Cap Growth Fund |
May 1, 2018
May 1, 2017 |
Variable Portfolio – Los Angeles Capital Large Cap Growth Fund
Variable Portfolio – Nuveen Winslow Large Cap Growth Fund |
VP – MFS Value Fund | May 1, 2018 | Variable Portfolio – MFS Value Fund |
VP – Morgan Stanley Advantage Fund |
May 1, 2018
May 1, 2016 |
Variable Portfolio – Morgan Stanley Advantage Fund
Variable Portfolio – Holland Large Cap Growth Fund |
VP – MV Moderate Growth Fund | May 1, 2018 | Columbia Variable Portfolio – Managed Volatility Moderate Growth Fund |
VP – Overseas Core Fund | May 1, 2018 | Columbia Variable Portfolio – Select International Equity Fund |
VP – Partners Core Bond Fund | May 1, 2017 | Variable Portfolio – J.P. Morgan Core Bond Fund |
VP – Partners Core Equity Fund |
May 20, 2019
May 1, 2018 May 1, 2016 |
CTIVP® – MFS® Blended Research® Core Equity Fund
Variable Portfolio – MFS® Blended Research® Core Equity Fund Variable Portfolio – Sit Dividend Growth Fund |
VP – Partners International Core Equity Fund |
May 1, 2020
May 21, 2018 May 1, 2018 |
CTIVP® – AQR International Core Equity Fund
CTIVP® – Pyramis® International Equity Fund Variable Portfolio – Pyramis International Equity Fund |
VP – Partners International Growth Fund |
May 1, 2020
May 20, 2019 May 1, 2018 May 1, 2016 |
CTIVP® – William Blair International Leaders Fund
CTIVP® – Oppenheimer International Growth Fund Variable Portfolio – Oppenheimer International Growth Fund Variable Portfolio – Invesco International Growth Fund |
VP – Partners International Value Fund |
May 1, 2020
May 1, 2018 |
CTIVP® – DFA International Value Fund
Variable Portfolio – DFA International Value Fund |
VP – Select Large Cap Value Fund | May 1, 2019 | Columbia Variable Portfolio – Select Large-Cap Value Fund |
VP – Select Mid Cap Value Fund | May 1, 2019 | Columbia Variable Portfolio – Mid Cap Value Fund |
VP – Select Small Cap Value Fund | May 1, 2019 | Columbia Variable Portfolio – Select Smaller-Cap Value Fund |
VP – T. Rowe Price Large Cap Value Fund |
May 1, 2018
November 14, 2016 |
Variable Portfolio – T. Rowe Price Large Cap Value Fund
Variable Portfolio – NFJ Dividend Value Fund |
VP – TCW Core Plus Bond Fund | May 1, 2018 | Variable Portfolio – TCW Core Plus Bond Fund |
VP – Victory Sycamore Established Value Fund |
May 1, 2018
May 1, 2016 |
Variable Portfolio – Victory Sycamore Established Value Fund
Variable Portfolio – Victory Established Value Fund |
VP – Wells Fargo Short Duration Government Fund | May 1, 2018 | Variable Portfolio – Wells Fargo Short Duration Government Fund |
VP – Westfield Mid Cap Growth Fund |
May 1, 2018
September 18, 2017 |
Variable Portfolio – Westfield Mid Cap Growth Fund
Variable Portfolio – Jennison Mid Cap Growth Fund |
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A. | Buy or sell real estate |
A1 – | The Fund will not buy or sell real estate, unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from investing in securities or other instruments backed by real estate or securities of companies engaged in the real estate business or real estate investment trusts. For purposes of this policy, real estate includes real estate limited partnerships. |
A2 – | The Fund will not buy or sell real estate, commodities or commodity contracts. For purposes of this policy, real estate includes real estate limited partnerships. |
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A3 – | The Fund will not purchase or hold any real estate, except the Fund may invest in securities secured by real estate or interests therein or issued by persons (including real estate investment trusts) which deal in real estate or interests therein. |
A4 – | The Fund will not buy or sell real estate, unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from investing in: (i) securities or other instruments backed by real estate or interests in real estate, (ii) securities or other instruments of issuers or entities that deal in real estate or are engaged in the real estate business, (iii) real estate investment trusts (REITs) or entities similar to REITs formed under the laws of non-U.S. countries or (iv) real estate or interests in real estate acquired through the exercise of its rights as a holder of securities secured by real estate or interests therein. |
B. | Buy or sell physical commodities |
B1 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options and futures contracts or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B2 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options, futures contracts and foreign currency or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B3 – | The Fund will not purchase or sell commodities or commodity contracts, except to the extent permissible under applicable law and interpretations, as they may be amended from time to time. |
B4 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options, futures contracts and foreign currency or from entering into forward currency contracts or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B5 – | The Fund will not buy or sell commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the fund from transacting in derivative instruments relating to commodities, including but not limited to, buying or selling options, swap contracts or futures contracts or from investing in securities or other instruments backed by, or whose value is derived from, commodities. |
B6 – | The Fund will not buy or sell commodities, except that the Fund may to the extent consistent with its investment objective(s), invest in securities of companies that purchase or sell commodities or which invest in such programs, and purchase and sell options, forward contracts, futures contracts, and options on futures contracts and enter into swap contracts and other financial transactions relating to commodities. This restriction does not apply to foreign currency transactions including without limitation forward currency contracts. This restriction also does not prevent the Fund from investing up to 25% of its total assets in one or more wholly-owned subsidiaries (as described further herein and referred to herein collectively as the “Subsidiary”), thereby gaining exposure to the investment returns of commodities markets within the limitations of the federal tax requirements.* |
B7 – | The Fund will not purchase or sell commodities, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
* | For purposes of the fundamental investment policy on buying and selling physical commodities above, at the time of the establishment of the restriction for certain Funds, swap contracts on financial instruments or rates were not within the understanding of the term “commodities.” Notwithstanding any federal legislation or regulatory action by the CFTC that subjects such swaps to regulation by the CFTC, these Funds will not consider such instruments to be commodities for purposes of this restriction. |
C. | Issuer Diversification*† |
C1 – | The Fund will not purchase more than 10% of the outstanding voting securities of an issuer, except that up to 25% of the Fund’s assets may be invested without regard to this 10% limitation. |
C2 – | The Fund will not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (a) up to 25% of its |
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total assets may be invested without regard to these limitations; and (b) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. | |
C3 – | The Fund will not purchase more than 10% of the outstanding voting securities of an issuer, except that up to 25% of the Fund’s assets may be invested without regard to this 10% limitation. For tax-exempt Funds, for purposes of this policy, the terms of a municipal security determine the issuer. |
* | For purposes of applying the limitation set forth in its issuer diversification policy above, a Fund does not consider futures or swaps central counterparties, where the Fund has exposure to such central counterparties in the course of making investments in futures and securities, to be issuers. |
† | For purposes of applying the limitation set forth in its issuer diversification policy, under certain circumstances, a Fund may treat an investment, if any, in a municipal bond refunded with escrowed U.S. Government securities as an investment in U.S. Government securities. |
D. | Lending |
D1 – | The Fund will not lend securities or participate in an interfund lending program if the total of all such loans would exceed 33 1⁄3% of the Fund’s total assets, except this fundamental investment policy shall not prohibit the Fund from purchasing money market securities, loans, loan participation or other debt securities, or from entering into repurchase agreements. |
D2 – | The Fund will not make loans, except as permitted by the 1940 Act or any rule thereunder, any SEC or SEC staff interpretations thereof or any exemptions therefrom which may be granted by the SEC. |
D3 – | The Fund will not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
E. | Act as an underwriter |
E1 – | The Fund will not act as an underwriter (sell securities for others). However, under the securities laws, the Fund may be deemed to be an underwriter when it purchases securities directly from the issuer and later resells them. |
E2 – | The Fund will not underwrite the securities of other issuers, except insofar as the Fund may be deemed an underwriter under the 1933 Act in disposing of a portfolio security or in connection with investments in other investment companies. |
E3 – | The Fund will not underwrite any issue of securities issued by other persons within the meaning of the 1933 Act except when it might be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer where the Fund later resells such securities. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered investment companies. |
F. | Borrowing |
F1 – | The Fund will not borrow money, except for temporary purposes (not for leveraging or investment) in an amount not exceeding 33 1⁄3% of its total assets (including the amount borrowed) less liabilities (other than borrowings) immediately after the borrowings. |
F2 – | The Fund will not issue senior securities or borrow money, except as permitted by the 1940 Act or any rule thereunder, any SEC or SEC staff interpretations thereof or any exceptions therefrom which may be granted by the SEC. For borrowing, the 1940 Act permits a fund to borrow up to 33 1⁄3% of its total assets (including the amounts borrowed) from banks, plus an additional 5% of its total assets for temporary purposes, which may be borrowed from banks or other sources. |
F3 – | The Fund will not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
G. | Issue senior securities |
G1 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H. | Concentration* |
H1 – | The Fund will not concentrate in any one industry. According to the present interpretation by the SEC, this means that up to 25% of the Fund’s total assets, based on current market value at time of purchase, can be invested in any one industry. |
H2 – | The Fund will, under normal market conditions, invest at least 25% of the value of its total assets at the time of purchase in the securities of issuers conducting their principal business activities in the technology and related group |
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of industries, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. | |
H3 – | While the Fund may invest 25% or more of its total assets in the securities of foreign governmental and corporate entities located in the same country, it will not invest 25% or more of its total assets in any single foreign governmental issuer. |
H4 – | The Fund will not invest more than 25% of the market value of its total assets in the securities of issuers in any particular industry, except the Fund will invest more than 25% of the value of its total assets in securities of issuers principally engaged in the real estate industry and may invest without limit in securities issued or guaranteed by the U.S. government or any of its agencies or instrumentalities. |
H5 – | The Fund will not invest 25% or more of its total assets in securities of corporate issuers engaged in any one industry. The foregoing restriction does not apply to securities issued or guaranteed by the U.S. government or any of its agencies or instrumentalities, or repurchase agreements secured by them. In addition, the foregoing restriction shall not apply to or limit the Fund’s counterparties in commodities-related transactions. |
H6 – | The Fund will not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H7 – | The Fund will not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
* | For purposes of applying the limitation set forth in its concentration policy, above, a Fund will generally use the industry classifications provided by the Global Industry Classification System (GICS) for classification of issuers of equity securities and the classifications provided by the Barclays Capital Aggregate Bond Index for classification of issues of fixed-income securities. A Fund does not consider futures or swaps clearinghouses or securities clearinghouses, where the Fund has exposure to such clearinghouses in the course of making investments in futures and securities, to be part of any industry. |
■ | Buy on margin or sell short or deal in options to buy or sell securities. |
■ | Purchase common stocks, preferred stocks, warrants, other equity securities, corporate bonds or debentures, state bonds, municipal bonds, or industrial revenue bonds. |
■ | Intentionally invest more than 25% of the Fund’s assets taken at market value in any particular industry, except with respect to investing in U.S. government or agency securities and bank obligations. Investments are varied according to what is judged advantageous under different economic conditions. |
■ | Purchase securities on margin except as permitted by the 1940 Act or any rule thereunder, any Securities and Exchange Commission (the “SEC”) or SEC staff interpretations thereof or any exemptions therefrom which may be granted by the SEC. |
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■ | Up to 25% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 20% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 20% of the Fund’s total assets may be invested in foreign investments. |
■ | Up to 15% of the Fund’s net assets may be invested in foreign investments. |
■ | The Fund will not (subject to the succeeding sentence) purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to government securities, cash and/or repurchase agreements collateralized solely by government securities or cash; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. If, at a future date, the Fund ceases to be a government money market fund and becomes a money market fund that may invest significantly in Rule 2a-7 eligible securities issued by non-government entities, the Fund may invest more than 25% of its total assets in money market instruments issued by U.S. banks or U.S. branches of foreign banks (subject to the applicable requirements of Rule 2a-7) and U.S. Government securities. |
■ | The Fund will not invest in oil, gas or other mineral exploration or development programs; provided, however, that this investment restriction shall not prohibit the fund from purchasing publicly-traded securities of companies engaging in whole or in part in such activities. |
■ | The Fund will not purchase securities from or sell securities to any of its officers or Trustees, except with respect to its own shares and as permissible under applicable statutes, rule ad regulations. |
■ | The Fund will not invest more than 5% of the value of its net assets, valued at the lower of cost or market, in warrants, of which no more than 2% of net assets may be invested in warrants and rights not listed on the New York or American Stock Exchange. For this purpose, warrants acquired by the fund in units or attached to securities may be deemed to have been purchased without cost. |
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Type of Investment |
Equity
and Flexible |
Funds-of-Funds
– Equity and Fixed Income |
Taxable
Fixed Income |
Money
Market |
Asset-Backed Securities | • | • | • | • |
Bank Obligations (Domestic and Foreign) | • | • | • | • |
Collateralized Bond Obligations | • | • | • | • |
Commercial Paper | • | • | • | • |
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Type of Investment |
Equity
and Flexible |
Funds-of-Funds
– Equity and Fixed Income |
Taxable
Fixed Income |
Money
Market |
Common Stock | • | • | •A | — |
Convertible Securities | • | • | • | — |
Corporate Debt Securities | • | • | • | •B |
Custody Receipts and Trust Certificates | • | • | • | • |
Debt Obligations | • | • | • | • |
Depositary Receipts | • | • | •C | — |
Derivatives | • | • | • | — |
Dollar Rolls | •D | • | • | — |
Exchange-Traded Notes | • | • | • | — |
Foreign Currency Transactions | • | • | • | — |
Foreign Securities | • | • | • | • |
Guaranteed Investment Contracts (Funding Agreements) | • | • | • | • |
High-Yield Securities | • | • | • | — |
Illiquid Investments | • | • | • | • |
Inflation-Protected Securities | • | • | • | — |
Initial Public Offerings | • | • | • | • |
Inverse Floaters | •E | • | • | — |
Investments in Other Investment Companies (Including ETFs) | • | • | • | • |
Listed Private Equity Funds | • | • | • | — |
Money Market Instruments | • | • | • | • |
Mortgage-Backed Securities | •F | • | • | • |
Municipal Securities | • | • | • | • |
Participation Interests | • | • | • | — |
Partnership Securities | • | • | • | — |
Preferred Stock | • | • | •G | — |
Private Placement and Other Restricted Securities | • | • | • | • |
Real Estate Investment Trusts | • | • | • | — |
Repurchase Agreements | • | • | • | • |
Reverse Repurchase Agreements | • | • | • | • |
Short Sales | • | • | • | — |
Sovereign Debt | • | • | • | • |
Standby Commitments | • | • | • | • |
U.S. Government and Related Obligations | • | • | • | • |
Variable- and Floating-Rate Obligations | •H | • | • | •I |
Warrants and Rights | • | • | • | — |
A. | The following Fund is not authorized to invest in Common Stock: VP – U.S. Government Mortgage Fund. |
B. | While the Fund is prohibited from investing in corporate bonds, it may invest in securities classified as corporate bonds if they meet the requirements of Rule 2a-7 of the 1940 Act. |
C. | The following Fund is not authorized to invest in Depository Receipts: VP – U.S. Government Mortgage Fund. |
D. | The following Funds are authorized to invest in Dollar Rolls: VP – Balanced Fund, VP – Commodity Strategy Fund, VP – Core Equity Fund, VP – Disciplined Core Fund and VP – Select Large Cap Equity Fund. |
E. | The following Funds are authorized to invest in Inverse Floaters: VP – Balanced Fund, VP – Commodity Strategy Fund, VP – Disciplined Core Fund and VP – Select Large Cap Equity Fund. |
F. | The following Funds are not authorized to invest in Mortgage-Backed Securities: VP – Large Cap Index Fund and VP – Select Small Cap Value Fund. |
G. | The following Fund is not authorized to invest in Preferred Stock: VP – U.S. Government Mortgage Fund. |
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H. | The following Funds are authorized to invest in Floating-Rate Loans: VP – Balanced, VP – Commodity Strategy Fund and VP – Select Large Cap Equity Fund. |
I. | The Fund is not authorized to invest in floating rate loans. This restriction is not intended to prevent the Fund from investing in variable and floating rate instruments that are permissible investments for money market funds under Rule 2a-7. |
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■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency hedging strategy by a Fund may be reduced by the Fund’s inability to precisely match forward contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. The Fund may use these instruments to gain leveraged exposure to currencies, which is a speculative investment practice that increases the Fund's risk exposure and the possibility of losses. Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A forward interest rate agreement is a derivative whereby the buyer locks in an interest rate at a future settlement date. If the interest rate on the settlement date exceeds the lock rate, the buyer pays the seller the difference between the two rates (based on the notional value of the agreement). If the lock rate exceeds the interest rate on the settlement date, the seller pays the buyer the difference between the two rates (based on the notional value of the agreement). The Fund may act as a buyer or a seller. |
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■ | A bond (or debt instrument) future is a derivative that is an agreement for the contract holder to buy or sell a bond or other debt instrument, a basket of bonds or other debt instrument, or the bonds or other debt instruments in an index on a specified date at a predetermined price. The buyer (long position) of a bond future is obliged to buy the underlying reference at the agreed price on expiry of the future. |
■ | A commodity-linked future is a derivative that is an agreement to buy or sell one or more commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures at a specific date in the future at a specific price. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
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■ | A commodity-linked structured note is a derivative (structured investment) that has principal and/or interest payments based on the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), a basket of commodities, indices of commodity futures or other economic variable. If payment of interest on a commodity-linked structured note is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might receive lower interest payments (or not receive any of the interest due) on its investments if there is a loss of value in the underlying reference. Further, to the extent that the amount of principal to be repaid upon maturity is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might not receive a portion (or any) of the principal at maturity of the investment or upon earlier exchange. At any time, the risk of loss associated with a particular structured note in the Fund’s portfolio may be significantly higher than the value of the note. A liquid secondary market may not exist for the commodity-linked structured notes held in the Fund’s portfolio, which may make it difficult for the notes to be sold at a price acceptable to the portfolio manager(s) or for the Fund to accurately value them. |
■ | An equity-linked note (ELN) is a derivative (structured investment) that has principal and/or interest payments based on the value of a single equity security, a basket of equity securities or an index of equity securities, and generally has risks similar to these underlying equity securities. ELNs may be leveraged or unleveraged. An ELN typically provides interest income, thereby offering a yield advantage over investing directly in an underlying equity. The Fund may purchase ELNs that trade on a securities exchange or those that trade on the over-the-counter markets, as well as in privately negotiated transactions with the issuer of the ELN. Investments in ELNs are also subject to liquidity risk, which may make ELNs difficult to sell and value. The liquidity of unlisted ELNs is normally determined by the willingness of the issuer to make a market in the ELN. While the Fund will seek to purchase ELNs only from issuers that it believes to be willing and able to repurchase the ELN at a reasonable price, there can be no assurance that the Fund will be able to sell at such a price. Furthermore, such inability to sell may impair the Fund’s ability to enter into other transactions at a time when doing so might be advantageous. The Fund’s investments in ELNs have the potential to lead to significant losses, including the amount the Fund invested in the ELN, because ELNs are subject to the market and volatility risks associated with their underlying equity. In addition, because ELNs often take the form of unsecured notes of the issuer, the Fund would be subject to the risk that the issuer may default on its obligations under the ELN, thereby subjecting the Fund to the further risk of being too concentrated in the securities (including ELNs) of that issuer. However, the Fund typically considers ELNs alongside other securities of the issuer in its assessment of issuer concentration risk. In addition, ELNs may exhibit price behavior that does not correlate with the underlying securities. ELNs may also be subject to leverage risk. The Fund may or may not hold an ELN until its maturity. ELNs also include participation notes. |
■ | A commodity-linked swap is a derivative (swap) that is an agreement where the underlying reference is the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit |
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default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
■ | An inflation rate swap is a derivative typically used to transfer inflation risk from one party to another through an exchange of cash flows. In an inflation rate swap, one party pays a fixed rate on a notional principal amount, while the other party pays a floating rate linked to an inflation index, such as the Consumer Price Index (CPI). |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including LIBOR, swap rates, treasury rates and foreign interest rates. |
■ | Total return swaps are derivative swap transactions in which one party agrees to pay the other party an amount equal to the total return of a defined underlying reference during a specified period of time. In return, the other party would make periodic payments based on a fixed or variable interest rate or on the total return of a different underlying reference. |
■ | Contracts for differences are swap arrangements in which the parties agree that their return (or loss) will be based on the relative performance of two different groups or baskets of securities or other instruments. Often, one or both baskets will be an established securities index. The Fund’s return will be based on changes in value of theoretical long futures positions in the securities comprising one basket (with an aggregate face value equal to the notional amount of the contract for differences) and theoretical short futures positions in the securities comprising the other basket. The Fund also may use actual long and short futures positions and achieve similar market exposure by netting the payment obligations of the two contracts. If the short basket outperforms the long basket, the Fund will realize a loss – even in circumstances when the securities in both the long and short baskets appreciate in value. |
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Fund |
Assets
(millions) |
Annual rate at
each asset level |
VP – American Century Diversified Bond Fund(a) | $0-$500 | 0.500% |
>$500-$1,000 | 0.495% | |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$12,000 | 0.410% | |
>$12,000-$20,000 | 0.390% | |
>$20,000-$24,000 | 0.380% | |
>$24,000-$50,000 | 0.360% | |
>$50,000 | 0.340% | |
VP – Balanced Fund | $0-$500 | 0.720% |
>$500-$1,000 | 0.670% | |
>$1,000-$1,500 | 0.620% | |
>$1,500-$3,000 | 0.570% | |
>$3,000-$6,000 | 0.550% | |
>$6,000-$12,000 | 0.530% | |
>$12,000 | 0.520% | |
VP – BlackRock Global Inflation-Protected Securities Fund | $0-$500 | 0.510% |
>$500-$1,000 | 0.505% | |
>$1,000-$2,000 | 0.475% | |
>$2,000-$3,000 | 0.450% | |
>$3,000-$6,000 | 0.415% | |
>$6,000-$7,500 | 0.390% | |
>$7,500-$9,000 | 0.375% | |
>$9,000-$10,000 | 0.370% | |
>$10,000-$12,000 | 0.360% | |
>$12,000-$15,000 | 0.350% | |
>$15,000-$20,000 | 0.340% | |
>$20,000-$24,000 | 0.330% | |
>$24,000-$50,000 | 0.310% | |
>$50,000 | 0.290% | |
VP – CenterSquare Real Estate Fund | $0-$500 | 0.750% |
>$500-$1,000 | 0.745% | |
>$1,000-$1,500 | 0.720% | |
>$1,500-$3,000 | 0.670% | |
>$3,000 | 0.660% | |
VP – Commodity Strategy Fund(b) | $0-$500 | 0.630% |
>$500-$1,000 | 0.580% | |
>$1,000-$3,000 | 0.550% | |
>$3,000-$6,000 | 0.520% | |
>$6,000-$12,000 | 0.500% | |
>$12,000 | 0.490% | |
VP – Core Equity Fund | All | 0.400% |
VP – Disciplined Core Fund
VP – Select Large Cap Value Fund |
$0-$500 | 0.770% |
>$500-$1,000 | 0.715% | |
>$1,000-$3,000 | 0.615% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Dividend Opportunity Fund | $0-$500 | 0.720% |
>$500-$1,000 | 0.670% | |
>$1,000-$1,500 | 0.620% | |
>$1,500-$3,000 | 0.570% | |
>$3,000-$6,000 | 0.550% | |
>$6,000-$12,000 | 0.530% | |
>$12,000 | 0.520% |
Statement of Additional Information – May 1, 2020 | 88 |
Fund |
Assets
(millions) |
Annual rate at
each asset level |
VP – Emerging Markets Bond Fund | $0-$500 | 0.600% |
>$500-$1,000 | 0.590% | |
>$1,000-$2,000 | 0.575% | |
>$2,000-$3,000 | 0.555% | |
>$3,000-$6,000 | 0.530% | |
>$6,000-$7,500 | 0.505% | |
>$7,500-$9,000 | 0.490% | |
>$9,000-$10,000 | 0.481% | |
>$10,000-$12,000 | 0.469% | |
>$12,000-$15,000 | 0.459% | |
>$15,000-$20,000 | 0.449% | |
>$20,000-$24,000 | 0.433% | |
>$24,000-$50,000 | 0.414% | |
>$50,000 | 0.393% | |
VP – Emerging Markets Fund(c) | $0-$500 | 1.100% |
>$500-$1,000 | 1.060% | |
>$1,000-$1,500 | 0.870% | |
>$1,500-$3,000 | 0.820% | |
>$3,000-$6,000 | 0.770% | |
>$6,000-$12,000 | 0.720% | |
>$12,000 | 0.700% | |
VP – Global Strategic Income Fund | $0-$500 | 0.650% |
>$500-$1,000 | 0.645% | |
>$1,000-$2,000 | 0.595% | |
>$2,000-$3,000 | 0.590% | |
>$3,000-$6,000 | 0.575% | |
>$6,000-$7,500 | 0.570% | |
>$7,500-$12,000 | 0.560% | |
>$12,000-$20,000 | 0.540% | |
>$20,000-$50,000 | 0.530% | |
>$50,000 | 0.520% | |
VP – Government Money Market Fund | $0-$500 | 0.390% |
>$500-$1,000 | 0.385% | |
>$1,000-$1,500 | 0.363% | |
>$1,500-$2,000 | 0.345% | |
>$2,000-$2,500 | 0.328% | |
>$2,500-$3,000 | 0.310% | |
>$3,000-$5,000 | 0.300% | |
>$5,000-$6,000 | 0.280% | |
>$6,000-$7,500 | 0.260% | |
>$7,500-$9,000 | 0.255% | |
>$9,000-$10,000 | 0.230% | |
>$10,000-$12,000 | 0.220% | |
>$12,000-$15,000 | 0.210% | |
>$15,000-$20,000 | 0.200% | |
>$20,000-$24,000 | 0.190% | |
>$24,000 | 0.180% | |
VP – High Yield Bond Fund
VP – Income Opportunities Fund |
$0-$250 | 0.660% |
>$250-$500 | 0.645% | |
>$500-$750 | 0.635% | |
>$750-$1,000 | 0.625% | |
>$1,000-$2,000 | 0.610% | |
>$2,000-$3,000 | 0.600% | |
>$3,000-$6,000 | 0.565% | |
>$6,000-$7,500 | 0.540% | |
>$7,500-$9,000 | 0.525% | |
>$9,000-$10,000 | 0.500% | |
>$10,000-$12,000 | 0.485% | |
>$12,000-$15,000 | 0.475% | |
>$15,000-$20,000 | 0.465% | |
>$20,000-$24,000 | 0.440% | |
>$24,000-$50,000 | 0.425% | |
>$50,000 | 0.400% |
Statement of Additional Information – May 1, 2020 | 89 |
Fund |
Assets
(millions) |
Annual rate at
each asset level |
VP – Intermediate Bond Fund | $0-$500 | 0.500% |
VP – TCW Core Plus Bond Fund | >$500-$1,000 | 0.495% |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.450% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$12,000 | 0.410% | |
>$12,000-$20,000 | 0.390% | |
>$20,000-$24,000 | 0.380% | |
>$24,000-$50,000 | 0.360% | |
>$50,000 | 0.340% | |
VP – Large Cap Growth Fund | $0-$500 | 0.770% |
VP – Partners Core Equity Fund | >$500-$1,000 | 0.720% |
VP – Victory Sycamore Established Value Fund | >$1,000-$1,500 | 0.670% |
>$1,500-$3,000 | 0.620% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Large Cap Index Fund | All | 0.200% |
VP – Limited Duration Credit Fund | $0-$500 | 0.480% |
>$500-$1,000 | 0.475% | |
>$1,000-$2,000 | 0.465% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$10,000 | 0.410% | |
>$10,000-$12,000 | 0.400% | |
>$12,000-$15,000 | 0.390% | |
>$15,000-$20,000 | 0.380% | |
>$20,000-$24,000 | 0.370% | |
>$24,000-$50,000 | 0.350% | |
>$50,000 | 0.330% | |
VP – Loomis Sayles Growth Fund | $0-$500 | 0.710% |
VP – MFS Value Fund | >$500-$1,000 | 0.705% |
VP – T. Rowe Price Large Cap Value Fund | >$1,000-$2,000 | 0.650% |
VP – Los Angeles Capital Large Cap Growth Fund | >$2,000-$3,000 | 0.550% |
>$3,000-$12,000 | 0.540% | |
>$12,000 | 0.530% | |
VP – Mid Cap Growth Fund | $0-$500 | 0.820% |
VP – Select Mid Cap Value Fund | >$500-$1,000 | 0.770% |
>$1,000-$1,500 | 0.720% | |
>$1,500-$3,000 | 0.670% | |
>$3,000-$12,000 | 0.660% | |
>$12,000 | 0.650% | |
VP – Morgan Stanley Advantage Fund | $0-$500 | 0.710% |
>$500-$1,000 | 0.705% | |
>$1,000-$1,500 | 0.650% | |
>$1,500-$2,000 | 0.600% | |
>$2,000-$3,000 | 0.550% | |
>$3,000-$12,000 | 0.540% | |
>$12,000 | 0.530% |
Statement of Additional Information – May 1, 2020 | 90 |
Fund |
Assets
(millions) |
Annual rate at
each asset level |
VP – Overseas Core Fund | $0-$250 | 0.880% |
>$250-$500 | 0.855% | |
>$500-$750 | 0.825% | |
>$750-$1,000 | 0.800% | |
>$1,000-$1,500 | 0.770% | |
>$1,500-$3,000 | 0.720% | |
>$3,000-$6,000 | 0.700% | |
>$6,000-$12,000 | 0.680% | |
>$12,000-$20,000 | 0.670% | |
>$20,000-$24,000 | 0.660% | |
>$24,000-$50,000 | 0.650% | |
>$50,000 | 0.620% | |
VP – Partners Core Bond Fund(d) | $0-$500 | 0.500% |
>$500-$1,000 | 0.495% | |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$12,000 | 0.410% | |
>$12,000-$20,000 | 0.390% | |
>$20,000-$24,000 | 0.380% | |
>$24,000-$50,000 | 0.360% | |
>$50,000 | 0.340% | |
VP – Partners International Core Equity Fund (e) | $0-$500 | 0.870% |
VP – Partners International Value Fund | >$500-$1,000 | 0.820% |
>$1,000-$1,500 | 0.770% | |
>$1,500-$3,000 | 0.720% | |
>$3,000-$6,000 | 0.700% | |
>$6,000-$12,000 | 0.680% | |
>$12,000 | 0.670% | |
VP – Partners International Growth Fund (f) | $0-$500 | 0.920% |
>$500-$1,000 | 0.870% | |
>$1,000-$1,500 | 0.820% | |
>$1,500-$3,000 | 0.770% | |
>$3,000-$12,000 | 0.760% | |
>$12,000 | 0.750% | |
VP – Select Large Cap Equity Fund | $0-$500 | 0.770% |
>$500-$1,000 | 0.720% | |
>$1,000-$1,500 | 0.670% | |
>$1,500-$3,000 | 0.620% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Select Small Cap Value Fund | $0-$500 | 0.870% |
VP – Partners Small Cap Growth Fund | >$500-$1,000 | 0.820% |
VP – Partners Small Cap Value Fund | >$1,000-$3,000 | 0.770% |
>$3,000-$12,000 | 0.760% | |
>$12,000 | 0.750% | |
VP – Seligman Global Technology Fund(c) | $0-$500 | 0.915% |
>$500-$1,000 | 0.910% | |
>$1,000-$3,000 | 0.905% | |
>$3,000-$4,000 | 0.865% | |
>$4,000-$6,000 | 0.815% | |
>$6,000-$12,000 | 0.765% | |
>$12,000 | 0.755% |
Statement of Additional Information – May 1, 2020 | 91 |
Fund |
Assets
(millions) |
Annual rate at
each asset level |
VP – U.S. Government Mortgage Fund | $0-$500 | 0.430% |
VP – Wells Fargo Short Duration Government Fund | >$500-$1,000 | 0.425% |
>$1,000-$2,000 | 0.415% | |
>$2,000-$3,000 | 0.410% | |
>$3,000-$6,000 | 0.395% | |
>$6,000-$7,500 | 0.380% | |
>$7,500-$9,000 | 0.365% | |
>$9,000-$10,000 | 0.360% | |
>$10,000-$12,000 | 0.350% | |
>$12,000-$15,000 | 0.340% | |
>$15,000-$20,000 | 0.330% | |
>$20,000-$24,000 | 0.320% | |
>$24,000-$50,000 | 0.300% | |
>$50,000 | 0.280% | |
VP – Westfield Mid Cap Growth Fund | $0-$500 | 0.810% |
>$500-$1,000 | 0.805% | |
>$1,000-$2,000 | 0.750% | |
>$2,000-$3,000 | 0.700% | |
>$3,000-$12,000 | 0.690% | |
>$12,000 | 0.680% |
(a) | Effective October 1, 2017, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(b) | When calculating asset levels for purposes of determining fee breakpoints, asset levels are based on net assets of the Fund, including assets invested in any wholly-owned subsidiary advised by the Investment Manager (“Subsidiaries”). Fees payable by the Fund under this agreement shall be reduced by any management services fees paid to the Investment Manager by any Subsidiaries under separate management agreements with the Subsidiaries. |
(c) | Effective July 1, 2017, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(d) | Effective May 1, 2017, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(e) | Effective May 1, 2018, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(f) | Effective July 1, 2018, the management fee schedule changed resulting in a fee rate decrease for certain asset levels. |
Statement of Additional Information – May 1, 2020 | 92 |
Management Services Fees | |||
2019 | 2018 | 2017 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $1,129,069 | $1,264,264 | $1,247,931 |
VP – American Century Diversified Bond Fund | 10,606,832 | 17,078,890 | 19,308,233 |
VP – Balanced Fund | 7,477,461 | 7,726,212 | 7,680,720 |
VP – BlackRock Global Inflation-Protected Securities Fund | 578,041 | 612,777 | 667,016 |
VP – CenterSquare Real Estate Fund | 3,811,958 | 3,316,890 | 3,272,698 |
VP – Commodity Strategy Fund | 2,527,621 | 2,784,979 | 3,069,259 |
VP – Conservative Portfolio | 563,358 | 566,496 | 572,643 |
VP – Core Equity Fund | 768,386 | 833,010 | 794,122 |
VP – Disciplined Core Fund | 33,524,090 | 34,505,935 | 32,503,049 |
VP – Dividend Opportunity Fund | 9,854,871 | 10,928,630 | 11,633,381 |
VP – Emerging Markets Bond Fund | 1,650,275 | 1,291,461 | 1,045,448 |
VP – Emerging Markets Fund | 4,899,467 | 6,650,856 | 8,027,715 |
VP – Global Strategic Income Fund | 740,869 | 840,798 | 969,123 |
VP – Government Money Market Fund | 1,549,508 | 1,559,441 | 1,286,289 |
VP – High Yield Bond Fund | 2,287,706 | 2,528,890 | 2,890,348 |
VP – Income Opportunities Fund | 2,261,803 | 2,285,519 | 2,447,154 |
VP – Intermediate Bond Fund | 21,572,199 | 21,886,451 | 23,459,005 |
VP – Large Cap Growth Fund | 13,196,923 | 12,978,676 | 11,991,456 |
VP – Large Cap Index Fund | 2,025,360 | 1,504,405 | 1,092,855 |
VP – Limited Duration Credit Fund | 3,661,210 | 3,756,689 | 3,999,936 |
VP – Loomis Sayles Growth Fund | 15,370,205 | 14,270,167 | 14,158,262 |
VP – Los Angeles Capital Large Cap Growth Fund | 12,558,137 | 11,755,200 | 9,163,893 |
VP – MFS Value Fund | 11,038,713 | 13,720,441 | 14,462,241 |
VP – Mid Cap Growth Fund | 4,111,647 | 4,079,235 | 3,729,665 |
VP – Moderate Portfolio | 6,458,492 | 6,547,026 | 6,746,570 |
VP – Moderately Aggressive Portfolio | 3,861,872 | 3,905,274 | 3,898,290 |
VP – Moderately Conservative Portfolio | 1,495,232 | 1,485,499 | 1,482,918 |
VP – Morgan Stanley Advantage Fund | 14,940,238 | 13,425,182 | 10,550,546 |
VP – MV Moderate Growth Fund | 25,436,718 | 25,710,531 | 24,333,980 |
VP – Overseas Core Fund | 9,290,306 | 9,486,691 | 8,756,694 |
VP – Partners Core Bond Fund | 17,140,949 | 15,258,927 | 16,120,935 |
VP – Partners Core Equity Fund | 14,475,930 | 13,965,602 | 12,970,751 |
VP – Partners International Core Equity Fund | 23,133,876 | 20,565,530 | 22,221,886 |
VP – Partners International Growth Fund | 7,761,679 | 13,859,903 | 16,869,111 |
VP – Partners International Value Fund | 7,210,107 | 13,175,262 | 14,355,711 |
VP – Partners Small Cap Growth Fund | 5,404,251 | 6,013,848 | 5,430,595 |
VP – Partners Small Cap Value Fund | 6,122,700 | 6,875,779 | 6,890,852 |
Statement of Additional Information – May 1, 2020 | 93 |
Management Services Fees | |||
2019 | 2018 | 2017 | |
VP – Select Large Cap Equity Fund | $9,017,547 | $4,672,522(a) | N/A |
VP – Select Large Cap Value Fund | 9,150,135 | 9,610,985 | $8,866,594 |
VP – Select Mid Cap Value Fund | 2,462,706 | 2,459,771 | 2,352,600 |
VP – Select Small Cap Value Fund | 737,036 | 848,498 | 923,607 |
VP – Seligman Global Technology Fund | 777,781 | 787,475 | 752,900 |
VP – T. Rowe Price Large Cap Value Fund | 13,532,956 | 15,460,008 | 15,499,079 |
VP – TCW Core Plus Bond Fund | 13,305,463 | 13,647,839 | 14,595,542 |
VP – U.S. Government Mortgage Fund | 4,226,983 | 4,277,183 | 4,634,190 |
VP – Victory Sycamore Established Value Fund | 4,703,484 | 4,589,674 | 4,039,577 |
VP – Wells Fargo Short Duration Government Fund | 8,257,971 | 4,440,155 | 4,350,639 |
VP – Westfield Mid Cap Growth Fund | 4,789,091 | 4,633,435 | 3,888,510 |
(a) | For the period from January 4, 2018 (commencement of operations) to December 31, 2018. |
Statement of Additional Information – May 1, 2020 | 94 |
Fund | Subadviser |
Parent
Company/Other Information |
Fee Schedule or Aggregate Effective Fee Rates |
VP – American Century Diversified Bond Fund |
American Century
(effective May 10, 2010) |
A | 0.160% on the first $500 million, declining to 0.080% as assets increase(a) |
VP – BlackRock Global Inflation-Protected Securities Fund(d) |
BlackRock
(effective October 19, 2012) |
B | 0.150% on the first $250 million, declining to 0.050% as assets increase |
Sub-Subadviser: BIL
(effective May 1, 2018) |
V | 50% of fee paid to BlackRock | |
VP – CenterSquare Real Estate Fund |
CenterSquare
(effective June 1, 2016) |
T | 0.400% on the first $200 million, declining to 0.300% as assets increase |
VP – Commodity Strategy Fund |
Threadneedle
(effective April 30, 2013) |
D | 0.250% on all assets |
VP – Loomis Sayles Growth Fund |
Loomis Sayles
(effective March 21, 2014) |
N | 0.265% on the first $3 billion, declining to 0.250% as assets increase(h) |
VP – Los Angeles Large Cap Growth Fund |
Los Angeles Capital
(effective May 1, 2017) |
J | 0.300% on the first $100 million, declining to 0.115% as assets increase(g) |
VP – MFS Value Fund |
MFS
(effective May 10, 2010) |
G | 0.350% on the first $100 million, declining to 0.175% as assets increase(a) |
VP – Morgan Stanley Advantage Fund |
MSIM
(effective May 2, 2016) |
H | 0.300% on the first $500 million, declining to 0.225% as assets increase |
VP – Overseas Core Fund |
Threadneedle
(effective July 9, 2004) |
D | 0.350% on all assets |
VP – Partners Core Bond Fund |
JPMIM
(effective May 10, 2010) WellsCap (effective May 1, 2017) |
E
K |
0.110% |
Statement of Additional Information – May 1, 2020 | 95 |
Fund | Subadviser |
Parent
Company/Other Information |
Fee Schedule or Aggregate Effective Fee Rates |
VP – Partners Core Equity Fund |
Jacobs Levy
(effective May 20, 2019) T. Rowe Price (effective May 20, 2019) |
L
I |
0.198%(f) |
VP – Partners International Core Equity Fund |
AQR
(effective on or about May 21, 2018) |
U | 0.260% on the first $500 million, declining to 0.205% as assets increase |
VP – Partners International Growth Fund |
William Blair
(effective May 20, 2019) |
O | 0.500% on the first $150 million, declining to 0.250% as assets increase |
VP – Partners International Value Fund |
DFA
(effective November 16, 2011) |
C | 0.210% on all asset levels |
VP – Partners Small Cap Growth Fund |
BMO
(effective May 1, 2017) Scout (effective May 20, 2019) WellsCap (effective May 10, 2010) |
R
W K |
0.349% |
VP – Partners Small Cap Value Fund |
Jacobs Levy
(effective May 1, 2017) Nuveen Asset Management (effective May 1, 2017) SBH (effective August 20, 2014) |
L
M P |
0.457% |
VP – T. Rowe Price Large Cap Value Fund |
T. Rowe Price
(effective November 14, 2016) |
I | 0.475% on the first $50 million, declining to 0.250% on all assets as asset levels increase(e)(f) |
VP – TCW Core Plus Bond Fund |
TCW
(effective March 21, 2014) |
Q | 0.180% on the first $500 million, declining to 0.050% as asset levels increase(b) |
VP – Victory Sycamore Established Value Fund |
Victory Capital
(effective November 16, 2012) |
S | 0.320% on the first $400 million, declining to 0.300% as assets increase |
VP – Wells Fargo Short Duration Government Fund |
WellsCap
(effective May 10, 2010) |
K | 0.150% on assets up to $250 million, declining to 0.120% as assets increase(c) |
VP – Westfield Mid Cap Growth Fund |
Westfield
(effective September 18, 2017) |
F | 0.400% on assets up to $250 million, declining to 0.300% as asset levels increase |
(a) | Effective October 1, 2017, the subadvisory fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(b) | The fee is calculated based on the combined net assets of certain Columbia Funds subject to the subadviser’s investment management. |
(c) | Effective May 1, 2017, the subadvisory fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(d) | BIL assists in providing day-to-day portfolio management to the Fund pursuant to the sub-subadvisory agreement with BlackRock. BlackRock will pay BIL for its services. |
(e) | Effective November 1, 2018, the subadvisory fee schedule changed resulting in a fee rate decrease for all asset levels. |
(f) | Effective May 20, 2019, T. Rowe Price has agreed to a voluntary subadvisory fee waiver arrangement whereby the subadvisory fee for the Fund (or portion thereof subadvised by T. Rowe Price) is reduced by 2.5% on combined assets of VP – T. Rowe Price Large Cap Value Fund and the portion of VP – Partners Core Equity Fund subadvised by T. Rowe Price up to $1 billion, increasing to 15% as combined assets increase. The fee rate reflects the rate that would have been paid to the subadvisers if they had subadvised the Fund in the last fiscal year. |
(g) | Effective December 1, 2019, the subadvisory fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(h) | Effective April 1, 2020, the subadvisory fee schedule changed resulting in a fee rate decrease for all asset levels. |
Statement of Additional Information – May 1, 2020 | 96 |
Statement of Additional Information – May 1, 2020 | 97 |
Statement of Additional Information – May 1, 2020 | 98 |
Subadvisory Fees Paid | ||||
Fund | Subadviser | 2019 | 2018 | 2017 |
VP – T. Rowe Price Large Cap Value Fund | T. Rowe Price | $4,843,071 | $6,307,215 | $6,489,285 |
VP – TCW Core Plus Bond Fund | TCW | 2,161,833 | 2,126,863 | 2,384,739 |
VP – Victory Sycamore Established Value Fund | Victory Capital | 1,959,446 | 1,898,484 | 1,679,794 |
VP – Wells Fargo Short Duration Government Fund | WellsCap | 2,350,271 | 1,245,853 | 1,323,244 |
VP – Westfield Mid Cap Growth Fund |
Former subadviser:
Jennison (5/10/2010 – 9/18/2017) |
N/A | N/A | 1,103,517 |
Westfield | 2,076,033 | 2,008,389 | 534,182(j) |
(a) | Threadneedle provided services to the Fund pursuant to the subadvisory agreement through December 9, 2019. Accordingly, the amount shown is for the period from January 1, 2019 to December 9, 2019. |
(b) | For the period from May 20, 2019 to December 31, 2019. |
(c) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2017, 2018, and 2019, which amounted to 0.123%, 0.110%, and 0.110%, respectively, of the Fund’s daily net assets as of each fiscal year end. |
(d) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2017, 2018, and 2019, which amounted to 0.164%, 0.226%, and 0.198%, respectively, of the Fund’s daily net assets as of each fiscal year end. |
(e) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2017, 2018, and 2019, which amounted to 0.430%, 0.401%, and 0.349%, respectively, of the Fund’s daily net assets as of each fiscal year end. |
(f) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2017, 2018, and 2019, which amounted to 0.491%, 0.460%, and 0.457%, respectively, of the Fund’s daily net assets as of each fiscal year end. |
(g) | For the period from May 21, 2018 to December 31, 2018. |
(h) | Threadneedle provided services to the Fund pursuant to the subadvisory agreement through May 1, 2018. Accordingly, the amount shown is for the period from January 1, 2018 to May 1, 2018. |
(i) | For the period from May 1, 2017 to December 31, 2017. |
(j) | For the period from September 18, 2017 to December 31, 2017. |
Statement of Additional Information – May 1, 2020 | 99 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – American Century Diversified Bond Fund |
American Century:
Alejandro Aguilar |
16 RICs 4 PIVs 2 other accounts |
$16.10 billion $2.44 billion $599.66 million |
None |
American Century |
American Century |
Robert Gahagan |
19 RICs
4 PIVs 2 other accounts |
$16.38 billion
$2.44 billion $599.66 million |
None | |||
Jeffrey Houston |
11 RICs
2 PIVs |
$9.13 billion
$1.95 billion |
None | |||
Brian Howell |
20 RICs
6 PIVs 7 other accounts |
$16.35 billion
$2.71 billion $1.75 billion |
None | |||
Charles Tan |
10 RICs
1 PIV |
$7.77 billion
$1.40 billion |
None | |||
VP – Balanced Fund | Gregory Liechty |
3 RICs
12 PIVs 42 other accounts |
$4.40 billion
$1.88 billion $4.34 billion |
None | Columbia Management | Columbia Management |
Guy Pope |
7 RICs
7 PIVs 102 other accounts |
$16.82 billion
$1.53 billion $2.75 billion |
None | |||
Ronald Stahl |
3 RICs
12 PIVs 42 other accounts |
$4.40 billion
$1.88 billion $4.61 billion |
None | |||
Jason Callan |
14 RICs
9 PIVs 5 other accounts |
$20.14 billion
$9.43 billion $1.30 million |
None | |||
VP – BlackRock Global Inflation-Protected Securities Fund |
BlackRock:
Akiva Dickstein |
12 RICs 12 PIVs 108 other accounts |
$12.37 billion $4.79 billion $64.15 billion |
6 PIVs ($3.62 B) 107 other accounts ($63.16 B) |
BlackRock |
BlackRock |
Emanuella Enenajor(a) |
6 RICs
3 PIVs 22 other accounts |
$4.22 billion
$572.70 million $11.83 billion |
1 PIV
($206.80 M) 22 other accounts ($11.83 B) |
|||
Sub-Subadviser: BIL:
Christopher Allen |
7 RICs
12 PIVs 25 other accounts |
$6.68 billion
$16.36 billion $11.92 billion |
5 PIVs
($2.56 B) 25 other accounts ($11.92 B) |
|||
VP – CenterSquare Real Estate Fund |
CenterSquare:
Dean Frankel |
5 RICs 8 PIVs 62 other accounts |
$2.08 billion $841.00 million $6.91 billion |
5 other accounts ($792.01 M) |
CenterSquare |
CenterSquare |
Eric Rothman |
4 RICs
4 PIVs 54 other accounts |
$1.39 billion
$147.00 million $5.08 billion |
3 other accounts
($421.91 M) |
|||
VP – Commodity Strategy Fund | Matthew Ferrelli |
2 RICs
2 other accounts |
$1.05 billion
$0.19 million |
None | Columbia Management | Columbia Management |
Marc Khalamayzer |
6 RICs
6 other accounts |
$1.10 billion
$0.49 million |
None |
Statement of Additional Information – May 1, 2020 | 100 |
Statement of Additional Information – May 1, 2020 | 101 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Global Strategic Income Fund | Gene Tannuzzo |
8 RICs
1 PIV 65 other accounts |
$14.49 billion
$84.11 million $1.64 billion |
None | Columbia Management | Columbia Management |
Ryan Staszewski | None | None | None | Threadneedle | Threadneedle | |
Tim Jagger |
3 RICs
1 PIV |
$739.39 million
$5.66 billion |
None | |||
VP – High Yield Bond Fund | Brian Lavin |
6 RICs
1 PIV 14 other accounts |
$3.16 billion
$292.73 million $1.45 billion |
None | Columbia Management | Columbia Management |
Daniel DeYoung |
3 RICs
5 other accounts |
$3.11 billion
$1.27 million |
None | |||
VP – Income Opportunities Fund | Brian Lavin |
6 RICs
1 PIV 14 other accounts |
$3.15 billion
$292.73 million $1.45 billion |
None | Columbia Management | Columbia Management |
Daniel DeYoung |
3 RICs
5 other accounts |
$3.10 billion
$1.27 million |
None | |||
VP – Intermediate Bond Fund | Gene Tannuzzo |
8 RICs
1 PIV 65 other accounts |
$9.94 billion
$84.11 million $1.64 billion |
None | Columbia Management | Columbia Management |
Jason Callan |
14 RICs
18 PIVs 5 other accounts |
$15.84 billion
$9.43 billion $1.30 million |
None | |||
VP – Large Cap Growth Fund | Melda Mergen |
6 RICs
17 other accounts |
$7.39 billion
$923.28 million |
None | Columbia Management | Columbia Management |
Peter Santoro |
6 RICs
1 PIV 59 other accounts |
$26.27 billion
$56.03 million $2.80 billion |
None | |||
Tchintcia Barros |
2 RICs
6 other accounts |
$5.26 billion
$322.28 million |
None | |||
VP – Large Cap Index Fund | Christopher Lo |
11 RICs
1 PIV 30 other accounts |
$11.76 billion
$98.10 million $224.45 million |
None | Columbia Management | Columbia Management |
Vadim Shteyn |
3 RICs
1 PIV 551 other accounts |
$11.36 billion
$98.10 million $589.10 million |
None | |||
VP – Limited Duration Credit Fund | Tom Murphy |
12 RICs
16 PIVs 22 other accounts |
$3.64 billion
$21.65 billion $4.32 billion |
None | Columbia Management | Columbia Management |
Royce Wilson |
1 RIC
4 other accounts |
$687.72 million
$0.62 million |
None | |||
John Dawson(c) | 6 other accounts | $1.25 million | None | |||
VP – Loomis Sayles Growth Fund |
Loomis Sayles:
Aziz Hamzaogullari |
31 RICs 25 PIVs 135 other accounts |
$25.52 billion $9.77 billion $23.20 billion |
2 PIVs ($777.21 M) |
Loomis Sayles |
Loomis Sayles |
Statement of Additional Information – May 1, 2020 | 102 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Los Angeles Large Cap Growth Fund |
Los Angeles Capital:
Thomas Stevens |
13 RICs 17 PIVs 37 other accounts |
$6.66 billion $4.89 billion $13.23 billion |
1 RIC ($3.91 B) 5 PIVs ($1.52 B) 6 other accounts ($7.56 B) |
Los Angeles Capital |
Los Angeles Capital |
Hal Reynolds |
13 RICs
17 PIVs 37 other accounts |
$6.66 billion
$4.89 billion $13.23 billion |
1 RIC
($3.91 B) 5 PIVs ($1.52 B) 6 other accounts ($7.56 B) |
|||
Daniel Allen |
9 RICs
17 PIVs 37 other accounts |
$1.98 billion
$4.89 billion $13.23 billion |
5 PIVs
($1.52 B) 6 other accounts ($7.56 B) |
|||
Daniel Arche |
1 RIC
5 PIVs 11 other accounts |
$830.00 million
$1.94 billion $2.25 billion |
3 PIVs
($840.00 M) |
|||
VP – MFS Value Fund |
MFS:
Katherine Cannan |
11 RICs 2 PIVs 18 other accounts |
$64.80 billion $3.30 billion $9.40 billion |
None |
MFS |
MFS |
Nevin Chitkara |
18 RICs
8 PIVs 39 other accounts |
$79.90 billion
$6.60 billion $19.60 billion |
None | |||
Steve Gorham(d) |
17 RICs
8 PIVs 39 other accounts |
$79.80 billion
$6.60 billion $19.60 billion |
None | |||
VP – Mid Cap Growth Fund | Matthew Litfin |
5 RICs
8 other accounts |
$6.89 billion
$22.99 million |
None | Columbia WAM | Columbia Management |
Erika Maschmeyer |
2 RICs
9 other accounts |
$5.89 billion
$17.02 million |
None | |||
John Emerson |
3 RICs
13 other accounts |
$2.09 billion
$17.30 million |
None | |||
VP – Moderate Portfolio | Joshua Kutin |
42 RICs
6 PIVs 29 other accounts |
$53.71 billion
$0.33 million $5.29 million |
None |
Columbia Management
- FoF |
Columbia Management |
David Weiss |
20 RICs
10 other accounts |
$48.74 billion
$1.90 million |
None | |||
Anwiti Bahuguna |
22 RICs
25 PIVs 35 other accounts |
$55.26 billion
$3.51 billion $115.53 million |
None | |||
Brian Virginia |
16 RICs
9 other accounts |
$49.03 billion
$3.10 million |
None |
Statement of Additional Information – May 1, 2020 | 103 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Moderately Aggressive Portfolio | Joshua Kutin |
42 RICs
6 PIVs 29 other accounts |
$63.14 billion
$0.33 million $5.29 million |
None |
Columbia Management
- FoF |
Columbia Management |
David Weiss |
20 RICs
10 other accounts |
$58.17 billion
$1.90 million |
None | |||
Anwiti Bahuguna |
22 RICs
25 PIVs 35 other accounts |
$64.69 billion
$3.51 billion $115.53 million |
None | |||
Brian Virginia |
16 RICs
9 other accounts |
$58.46 billion
$3.10 million |
None | |||
VP – Moderately Conservative Portfolio | Joshua Kutin |
42 RICs
6 PIVs 29 other accounts |
$67.88 billion
$0.33 million $5.29 million |
None |
Columbia Management
- FoF |
Columbia Management |
David Weiss |
20 RICs
10 other accounts |
$62.91 billion
$1.90 million |
None | |||
Anwiti Bahuguna |
22 RICs
25 PIVs 35 other accounts |
$69.43 billion
$3.51 billion $115.53 million |
None | |||
Brian Virginia |
16 RICs
9 other accounts |
$63.20 billion
$3.10 million |
None | |||
VP – Morgan Stanley Advantage Fund |
MSIM:
Dennis Lynch |
21 RICs 17 PIVs 17 other accounts |
$17.29 billion $13.96 billion $3.80 billion |
2 other accounts ($527.10 M) |
MSIM |
MSIM |
Sam Chainani |
20 RICs
16 PIVs 16 other accounts |
$17.28 billion
$13.95 billion $3.69 billion |
2 other accounts ($527.10 M) | |||
Jason Yeung |
20 RICs
16 PIVs 16 other accounts |
$17.28 billion
$13.95 billion $3.69 billion |
2 other accounts ($527.10 M) | |||
Armistead Nash |
20 RICs
16 PIVs 16 other accounts |
$17.28 billion
$13.95 billion $3.69 billion |
2 other accounts ($527.10 M) | |||
David Cohen |
20 RICs
16 PIVs 16 other accounts |
$17.28 billion
$13.95 billion $3.69 billion |
2 other accounts ($527.10 M) | |||
Alexander Norton |
20 RICs
16 PIVs 16 other accounts |
$17.28 billion
$13.95 billion $3.69 billion |
2 other accounts ($527.10 M) | |||
VP – MV Moderate Growth Fund | Joshua Kutin |
42 RICs
6 PIVs 29 other accounts |
$55.67 billion
$0.33 million $5.29 million |
None |
Columbia Management
- FoF |
Columbia Management |
David Weiss |
20 RICs
10 other accounts |
$50.70 billion
$1.90 million |
None | |||
Anwiti Bahuguna |
22 RICs
25 PIVs 35 other accounts |
$57.22 billion
$3.51 billion $115.53 million |
None | |||
Brian Virginia |
16 RICs
9 other accounts |
$50.99 billion
$3.10 million |
None |
Statement of Additional Information – May 1, 2020 | 104 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Overseas Core Fund | Fred Copper |
6 RICs
7 other accounts |
$3.12 billion
$131.32 million |
None | Columbia Management | Columbia Management |
Daisuke Nomoto |
5 RICs
1 PIV 4 other accounts |
$2.46 billion
$1.11 billion $3.08 million |
None | |||
VP – Partners Core Bond Fund |
JPMIM:
Richard Figuly |
23 RICs 13 PIVs 16 other accounts |
$64.90 billion $17.10 billion $6.30 billion |
1 other account ($1.02 B) |
JPMIM |
JPMIM |
Justin Rucker |
12 RICs
7 PIVs 24 other accounts |
$44.20 billion
$13.07 billion $9.40 billion |
1 other account
($1.02 B) |
|||
WellsCap:
Thomas O’Connor(e) |
8 RICs 5 PIVs 36 other accounts |
$18.34 billion $3.12 billion $13.51 billion |
1 PIV ($50.62 M) 2 other accounts ($841.99 M) |
WellsCap |
WellsCap |
|
Maulik Bhansali |
8 RICs
5 PIVs 36 other accounts |
$18.34 billion
$3.12 billion $13.51 billion |
1 PIV
($50.62 M) 2 other accounts ($841.99 M) |
|||
Jarad Vasquez |
8 RICs
5 PIVs 36 other accounts |
$18.34 billion
$3.12 billion $13.51 billion |
1 PIV
($50.62 M) 2 other accounts ($841.99 M) |
|||
VP – Partners Core Equity Fund |
Jacobs Levy:
Bruce Jacobs |
11 RICs 19 PIVs 99 other accounts |
$2.66 billion $2.45 billion $7.36 billion |
1 PIV ($110.52 M) 8 other accounts ($2.21 B) |
Jacobs Levy |
Jacobs Levy |
Kenneth Levy |
11 RICs
19 PIVs 99 other accounts |
$2.66 billion
$2.45 billion $7.36 billion |
1 PIV
($110.52 M) 8 other accounts ($2.21 B) |
|||
T. Rowe Price:
Jeffrey Rottinghaus |
2 RICs 8 PIVs 1 other account |
$3.01 billion $3.60 billion $2.53 million |
None |
T. Rowe Price |
T. Rowe Price |
Statement of Additional Information – May 1, 2020 | 105 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Partners International Core Equity Fund |
AQR:
Michele Aghassi |
11 RICs 13 PIVs 13 other accounts |
$8.68 billion $7.13 billion $4.83 billion |
2 RICs ($187.58 M) 10 PIVs ($4.92 B) 4 other accounts ($1.81 B) |
AQR |
AQR |
Andrea Frazzini |
28 RICs
20 PIVs 30 other accounts |
$16.32 billion
$10.32 billion $15.67 billion |
2 RICs
($187.58 M) 17 PIVs ($8.11 B) 7 other accounts ($2.01 B) |
|||
Ronen Israel(c) |
27 RICs
51 PIVs 49 other accounts |
$12.50 billion
$21.01 billion $25.40 billion |
46 PIVs
($18.59 B) 17 other accounts ($7.84 B) |
|||
Lars Nielsen(c) |
28 RICs
51 PIVs 49 other accounts |
$12.66 billion
$21.01 billion $25.40 billion |
46 PIVs
($18.59 B) 17 other accounts ($7.84 B) |
|||
VP – Partners International Growth Fund |
William Blair:
Simon Fennell |
10 RICs 20 PIVs 40 other accounts |
$8.35 billion $4.29 billion $10.69 billion |
None |
William Blair |
William Blair |
Kenneth McAtamney |
10 RICs
25 PIVs 39 other accounts |
$8.21 billion
$4.02 billion $12.20 billion |
None | |||
VP – Partners International Value Fund |
DFA:
Jed Fogdall |
110 RICs
25 PIVs 78 other accounts |
$428.83 billion
$18.97 billion $28.69 billion |
1 PIV
($180.14 M) 6 other accounts ($3.95 B) |
DFA |
DFA |
Bhanu Singh |
48 RICs
1 PIV 1 other account |
$197.78 billion
$50.20 million $598.71 million |
||||
Mary Philips |
74 RICs
2 PIVs |
$215.24 billion
$2.34 billion |
None | |||
Arun Keswani(f) |
20 RICs
10 other accounts |
$47.19 billion
$3.80 billion |
3 other accounts
($2.49 B) |
Statement of Additional Information – May 1, 2020 | 106 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Partners Small Cap Growth Fund |
BMO:
David Corris |
9 RICs 16 PIVs 111 other accounts |
$1.70 billion $3.54 billion $6.49 billion |
None |
BMO |
BMO |
Thomas Lettenberger |
5 RICs
6 PIVs 30 other accounts |
$428.24 million
$452.91 million $603.28 million |
None | |||
Scout:
James McBride |
1 RIC 3 other accounts |
$336.22 million $9.84 million |
None |
Scout |
Scout |
|
Timothy Miller |
1 RIC
3 other accounts |
$336.22 million
$9.84 million |
None | |||
WellsCap:
Thomas Ognar |
7 RICs 5 PIVs 44 other accounts |
$9.69 billion $1.29 billion $1.22 billion |
None |
WellsCap |
WellsCap |
|
Joseph Eberhardy |
7 RICs
5 PIVs 44 other accounts |
$9.69 billion
$1.29 billion $1.22 billion |
None | |||
VP – Partners Small Cap Value Fund |
Jacobs Levy:
Bruce Jacobs |
11 RICs 19 PIVs 99 other accounts |
$4.27 billion $2.45 billion $7.36 billion |
1 PIV ($110.52 M) 8 other accounts ($2.21 B) |
Jacobs Levy |
Jacobs Levy |
Kenneth Levy |
11 RICs
19 PIVs 99 other accounts |
$4.27 billion
$2.45 billion $7.36 billion |
1 PIV
($110.52 M) 8 other accounts ($2.21 B) |
|||
Nuveen Asset Management:
Karen Bowie |
None |
None |
None |
Nuveen Asset Management |
Nuveen Asset Management |
|
SBH:
Mark Dickherber |
3 RICs 77 other accounts |
$217.50 million $836.70 million |
None |
SBH |
SBH |
|
Shaun Nicholson |
2 RICs
42 other accounts |
$179.40 million
$458.80 million |
None | |||
VP – Select Large Cap Equity Fund | Peter Santoro |
6 RICs
1 PIV 59 other accounts |
$26.98 billion
$56.03 million $2.80 billion |
None | Columbia Management | Columbia Management |
Melda Mergen |
6 RICs
17 other accounts |
$8.11 billion
$923.28 million |
None | |||
Tiffany Wade |
2 RICs
9 other accounts |
$914.81 million
$485.14 million |
||||
VP – Select Large Cap Value Fund | Richard Rosen |
2 RICs
308 other accounts |
$1.46 billion
$2.68 billion |
None | Columbia Management | Columbia Management |
Richard Taft |
2 RICs
308 other accounts |
$1.46 billion
$2.67 billion |
None | |||
VP – Select Mid Cap Value Fund | Kari Montanus |
3 RICs
16 other accounts |
$2.17 billion
$21.38 million |
None | Columbia Management | Columbia Management |
Jonas Patrikson |
3 RICs
19 other accounts |
$2.17 billion
$20.98 million |
None |
Statement of Additional Information – May 1, 2020 | 107 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure of
Compensation |
VP – Select Small Cap Value Fund | Kari Montanus |
3 RICs
16 other accounts |
$2.41 billion
$21.38 million |
None | Columbia Management | Columbia Management |
Jonas Patrikson |
3 RICs
19 other accounts |
$2.41 billion
$20.98 million |
None | |||
VP – Seligman Global Technology Fund | Paul Wick |
4 RICs
4 PIVs 5 other accounts |
$8.78 billion
$1.09 billion $258.35 million |
2 PIVs
($670.43 M) |
Columbia Management |
Columbia Management
– Tech Team |
Shekhar Pramanick |
4 RICs
5 other accounts |
$8.78 billion
$6.31 million |
None | |||
Sanjay Devgan |
3 RICs
3 other accounts |
$8.41 billion
$1.86 million |
None | |||
Jeetil Patel |
4 RICs
6 other accounts |
$8.78 billion
$3.27 million |
None | |||
Christopher Boova |
4 RICs
7 other accounts |
$8.78 billion
$6.32 million |
None | |||
Vimal Patel |
4 RICs
7 other accounts |
$8.78 billion
$3.71 million |
None | |||
VP – T. Rowe Price Large Cap Value Fund |
T. Rowe Price:
Heather McPherson |
5 RICs 8 PIVs 19 other accounts |
$11.85 billion $1.98 billion $4.74 billion |
None |
T. Rowe Price |
T. Rowe Price |
Mark Finn |
10 RICs
15 PIVs 23 other accounts |
$43.31 billion
$24.69 billion $6.06 billion |
None | |||
John Linehan |
16 RICs
18 PIVs 27 other accounts |
$40.53 billion
$15.18 billion $6.40 billion |
None | |||
VP – TCW Core Plus Bond Fund |
TCW:
Tad Rivelle |
31 RICs 48 PIVs 219 other accounts |
$112.18 billion $16.64 billion $50.53 billion |
26 PIVs ($3.71 B) 8 other accounts ($4.60 B) |
TCW |
TCW |
Laird Landmann |
29 RICs
20 PIVs 192 other accounts |
$106.80 billion
$10.26 billion $40.38 billion |
3 PIVs
($640.97 M) 7 other accounts ($4.42 B) |
|||
Stephen Kane |
32 RICs
29 PIVs 202 other accounts |
$106.85 billion
$13.78 billion $44.75 billion |
9 PIVs
($2.95 B) 7 other accounts ($4.42 B) |
|||
Bryan Whalen |
29 RICs
40 PIVs 211 other accounts |
$112.16 billion
$13.18 billion $46.41 billion |
20 PIVs
($1.40 B) 8 other accounts ($4.60 B) |
|||
VP – U.S. Government Mortgage Fund | Jason Callan |
14 RICs
9 PIVs 5 other accounts |
$19.49 billion
$9.43 billion $1.30 million |
None | Columbia Management | Columbia Management |
Tom Heuer |
4 RICs
5 other accounts |
$4.04 billion
$3.28 million |
None | |||
Ryan Osborn |
3 RICs
6 other accounts |
$4.03 billion
$1.72 million |
None |
Statement of Additional Information – May 1, 2020 | 108 |
* | RIC refers to a Registered Investment Company; PIV refers to a Pooled Investment Vehicle. |
** | Number of accounts for which the advisory fee paid is based in part or wholly on performance and the aggregate net assets in those accounts. |
(a) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of February 29, 2020. |
(b) | Mr. Condon expects to retire effective May 31, 2020. Accordingly, effective June 1, 2020, all references to Mr. Condon in the SAI for the Fund are hereby removed. |
(c) | The portfolio manager began managing the Fund after its last fiscal year end. |
(d) | Mr. Gorham will no longer serve as portfolio manager of the Fund effective December 31, 2020. As of such date, all references to Mr. Gorham in the SAI for the Fund are hereby removed. |
(e) | Mr. O’Connor expects to retire effective December 31, 2020. Accordingly, effective January 1, 2021, all references to Mr. O’Connor in the SAI for the Fund are hereby removed. |
(f) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of March 31, 2020. |
Statement of Additional Information – May 1, 2020 | 109 |
AQR: Each of the portfolio managers is also responsible for managing other accounts in addition to the respective Fund the portfolio manager manages, including other accounts of AQR, or its affiliates. Other accounts may include, without limitation, separately managed accounts for foundations, endowments, pension plans, and high net-worth families; registered investment companies; unregistered investment companies relying on either Section 3(c)(1) or Section 3(c)(7) of the 1940 Act (such companies are commonly referred to as “hedge funds”); foreign investment companies; and may also include accounts or investments managed or made by the portfolio managers in a personal or other capacity (“Proprietary Accounts”). Management of other accounts in addition to the Fund can present certain conflicts of interest, as described below. |
From time to time, potential conflicts of interest may arise between a portfolio manager’s management of the investments of the Fund, on the one hand, and the management of other accounts (including for the purposes of this discussion, Proprietary Accounts), on the other. The other accounts might have similar investment objectives or strategies as the Fund, or otherwise hold, purchase, or sell securities that are eligible to be held, purchased or sold by the Fund. Because of their positions with the Fund, the portfolio managers know the size, timing and possible market impact of the Fund's trades. A potential conflict of interest exists where portfolio managers could use this information to the advantage of other accounts they manage and to the possible detriment of the Fund. |
Statement of Additional Information – May 1, 2020 | 110 |
A number of potential conflicts of interest may arise as a result of AQR’s or the portfolio manager’s management of a number of accounts with similar investment strategies. Often, an investment opportunity may be suitable for both the Fund and other accounts, but may not be available in sufficient quantities for both the Fund and the other accounts to participate fully. Similarly, there may be limited opportunity to sell an investment held by the Fund and another account. In circumstances where the amount of total exposure to a strategy or investment type across accounts is, in the opinion of AQR, capacity constrained, the availability of the strategy or investment type for the Fund and other accounts may be reduced in AQR’s discretion. The Fund may therefore have reduced exposure to a capacity constrained strategy or investment type, which could adversely affect the Fund's return. AQR is not obligated to allocate capacity pro rata and may take its financial interests into account when allocating capacity among the Fund and other accounts. Among other things, capacity constraints in a particular strategy or investment type could cause the Fund to close to all or certain new investors |
Another conflict could arise where different account guidelines and/or differences within particular investment strategies may lead to the use of different investment practices for portfolios with a similar investment strategy. AQR will not necessarily purchase or sell the same instruments at the same time or in the same direction (particularly if different accounts have different strategies), or in the same proportionate amounts for all eligible accounts (particularly if different accounts have materially different amounts of capital under management, different amounts of investable cash available, different investment restrictions, or different risk tolerances). As a result, although AQR manages numerous accounts and/or portfolios with similar or identical investment objectives, or may manage accounts with different objectives that trade in the same instruments, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, may differ from account to account. AQR may, from time to time, implement new trading strategies or participate in new trading strategies for some but not all accounts, including the Fund. Strategies may not be implemented in the same manner among accounts where they are employed, even if the strategy is consistent with the objectives of such accounts. In certain circumstances, investment opportunities that are in limited supply and/or have limited return potential in light of administrative costs of pursuing such investments (e.g., IPOS) are only allocated to accounts where the given opportunity is more closely aligned with the applicable strategy and/or trading approach. |
Whenever decisions are made to buy or sell investments by the Fund and one or more other accounts simultaneously, AQR or the portfolio manager may aggregate the purchases and sales of the investments and will allocate the transactions in a manner that it believes to be equitable under the circumstances. To this end, AQR has adopted policies and procedures that are intended to assure that investment opportunities are allocated equitably among accounts over time. As a result of the allocations, there may be instances where the Fund will not participate in a transaction that is allocated among other accounts or the Fund may not be allocated the full amount of the investments sought to be traded. These aggregation and allocation policies could have a detrimental effect on the price or amount of the investments available to the Fund from time to time. Subject to applicable laws and/or account restrictions, AQR may buy, sell or hold securities for other accounts while entering into a different or opposite investment decision for one or more funds. |
To the extent that the Fund holds interests in an issuer that are different (or more senior or junior) than, or potentially adverse to, those held by other accounts, AQR may be presented with investment decisions where the outcome would benefit one account and would not benefit or would harm the other account. This may include, but is not limited to, an account investing in a different security of an issuer’s capital structure than another account, an account investing in the same security but on different terms than another account, an account obtaining exposure to an investment using different types of securities or instruments than another account, an account engaging in short selling of securities that another account holds long, an account voting securities in a different manner than another account, and/or an account acquiring or disposing of its interests at different times than another account. This could have a material adverse effect on, or in some instances could benefit, one or more of such accounts, including accounts that are affiliates of AQR, accounts in which AQR has an interest, or accounts which pay AQR higher fees or a performance fee. These transactions or investments by one or more accounts could dilute or otherwise disadvantage the values, prices, or investment strategies of such accounts. When AQR, on behalf of an account, manages or implements a portfolio decision ahead of, or contemporaneously with, portfolio decisions of another account, market impact, liquidity constraints, or other factors could result in such other account receiving less favorable pricing or trading results, paying higher transaction costs, or being otherwise disadvantaged. In addition, in connection with the foregoing, AQR, on behalf of an account, is permitted to pursue or enforce rights or actions, or refrain from pursuing or enforcing rights or actions, with respect to a particular issuer in which action could materially adversely affect such other account. |
In addition, when the Fund and other accounts hold investments in the same issuer (including at the same place in the capital structure), the Fund may be prohibited by applicable law from participating in restructurings, work-outs or other activities related to its investment in the issuer. As a result, the Fund may not be permitted by law to make the same investment decisions as other accounts in the same or similar situations even if AQR believes it would be in the Fund's best economic interests to do so. The Fund may be prohibited by applicable law from investing in an issuer (or an affiliate) that other accounts are also investing in or currently invest in even if AQR believes it would be in the best economic interests of |
Statement of Additional Information – May 1, 2020 | 111 |
the Fund to do so. Furthermore, entering into certain transactions that are not deemed prohibited by law when made may potentially lead to a condition that raises regulatory or legal concerns in the future. This may be the case, for example, with issuers that AQR considers to be at risk of default and restructuring or work-outs with debt holders, which may include the Fund and other accounts. In some cases, to avoid the potential of future prohibited transactions, AQR may avoid allocating an investment opportunity to the Fund that it would otherwise recommend, subject to the AQR’s then- current allocation policy and any applicable exemptions. |
In certain circumstances, AQR may be restricted from transacting in a security or instrument because of material nonpublic information received in connection with an investment opportunity that is offered to AQR. In other circumstances, AQR will not participate in an investment opportunity to avoid receiving material nonpublic information that would restrict AQR from transacting in a security or instrument. These restrictions may adversely impact the Fund's performance. |
AQR and the Fund's portfolio managers may also face a conflict of interest where some accounts pay higher fees to AQR than others, as they may have an incentive to favor accounts with the potential for greater fees. For instance, the entitlement to a performance fee in managing one or more accounts may create an incentive for AQR to take risks in managing assets that it would not otherwise take in the absence of such arrangements. Additionally, since performance fees reward AQR for performance in accounts which are subject to such fees, AQR may have an incentive to favor these accounts over those that have only fixed asset-based fees, such as the Fund, with respect to areas such as trading opportunities, trade allocation, and allocation of new investment opportunities. |
AQR has implemented specific policies and procedures (e.g., a code of ethics and trade allocation policies) that seek to address potential conflicts of interest that may arise in connection with the management of the Fund and other accounts and that are designed to ensure that all accounts, including the Fund, are treated fairly and equitably over time. | |
BlackRock: BlackRock has built a professional working environment, firm-wide compliance culture and compliance procedures and systems designed to protect against potential incentives that may favor one account over another. BlackRock has adopted policies and procedures that address the allocation of investment opportunities, execution of portfolio transactions, personal trading by employees and other potential conflicts of interest that are designed to ensure that all client accounts are treated equitably over time. Nevertheless, BlackRock furnishes investment management and advisory services to numerous clients in addition to the Fund, and BlackRock may, consistent with applicable law, make investment recommendations to other clients or accounts (including accounts which are hedge funds or have performance or higher fees paid to BlackRock, or in which portfolio managers have a personal interest in the receipt of such fees), which may be the same as or different from those made to the Fund. In addition, BlackRock, its affiliates and significant shareholders and any officer, director, shareholder or employee may or may not have an interest in the securities whose purchase and sale BlackRock recommends to the Fund. BlackRock, or any of its affiliates or significant shareholders, or any officer, director, shareholder, employee or any member of their families may take different actions than those recommended to the Fund by BlackRock with respect to the same securities. Moreover, BlackRock may refrain from rendering any advice or services concerning securities of companies of which any of BlackRock’s (or its affiliates’ or significant shareholders’) officers, directors or employees are directors or officers, or companies as to which BlackRock or any of its affiliates or significant shareholders or the officers, directors and employees of any of them has any substantial economic interest or possesses material non-public information. Certain portfolio managers also may manage accounts whose investment strategies may at times be opposed to the strategy utilized for a fund. It should also be noted that Mr. Dickstein and Ms. Enenajor may be managing hedge fund and/or long only accounts, or may be part of a team managing hedge fund and/or long only accounts, subject to incentive fees. Mr. Dickstein and Ms. Enenajor may therefore be entitled to receive a portion of any incentive fees earned on such accounts. |
As a fiduciary, BlackRock owes a duty of loyalty to its clients and must treat each client fairly. When BlackRock purchases or sells securities for more than one account, the trades must be allocated in a manner consistent with its fiduciary duties. BlackRock attempts to allocate investments in a fair and equitable manner among client accounts, with no account receiving preferential treatment. To this end, BlackRock has adopted policies that are intended to ensure reasonable efficiency in client transactions and provide BlackRock with sufficient flexibility to allocate investments in a manner that is consistent with the particular investment discipline and client base, as appropriate. | |
Sub-Subadviser BIL: For Potential Conflicts of Interest information, reference Potential Conflicts of Interest: BlackRock. |
BMO: A conflict of interest may arise as a result of a portfolio manager being responsible for multiple accounts, including the Fund, which may have different investment guidelines and objectives. In addition to the Fund, these accounts may include other mutual funds managed on an advisory or subadvisory basis, separate accounts, and collective trust accounts. An investment opportunity may be suitable for a Fund as well as for any of the other managed accounts. However, the investment may not be available in sufficient quantity for all of the accounts to participate fully. In addition, there may be limited opportunity to sell an investment held by a Fund and the other accounts. The other accounts may have similar investment objectives or strategies as the Fund, they may track the same benchmarks or indexes as the Fund tracks, and they |
Statement of Additional Information – May 1, 2020 | 112 |
may sell securities that are eligible to be held, sold or purchased by the Fund. A portfolio manager may be responsible for accounts that have different advisory fee schedules, which may create the incentive for the portfolio manager to favor one account over another in terms of access to investment opportunities. A portfolio manager also may manage accounts whose investment objectives and policies differ from those of the Fund, which may cause the portfolio manager to effect trading in one account that may have an adverse effect on the value of the holdings within another account, including a Fund. |
To address and manage these potential conflicts of interest, BMO has adopted compliance policies and procedures to allocate investment opportunities and to ensure that each of its clients is treated on a fair and equitable basis. Such policies and procedures include, but are not limited to, trade allocation and trade aggregation policies, cross trading policies, portfolio manager assignment practices, and oversight by investment management, and/or compliance departments. |
CenterSquare: From time to time, potential conflicts of interest may arise between a portfolio manager’s management of the investments of the Fund, on the one hand, and the management of other accounts, on the other. The portfolio managers oversee the investment of various types of accounts in the same strategy, such as mutual funds, pooled investment vehicles and separate accounts for individuals and institutions. Investment decisions generally are applied to all accounts utilizing that particular strategy, taking into consideration client restrictions, instructions and individual needs. A portfolio manager may manage an account whose fees may be higher or lower than the fee charged to the Fund to provide for varying client circumstances. Management of multiple funds and accounts may create potential conflicts of interest relating to the allocation of investment opportunities, and the aggregation and allocation of client trades. Additionally, the management of the Fund and other accounts may result in a portfolio manager devoting unequal time and attention to the management of the Fund or other accounts. | |
During the normal course of managing assets for multiple clients of varying types and asset levels, the portfolio managers may encounter conflicts of interest, that could, if not properly addressed, be harmful to one or more of our clients. Those of a material nature that are encountered most frequently involve security selection, employee personal securities trading, proxy voting and the allocation of securities. To mitigate these conflicts and ensure its clients are not impacted negatively by the adverse actions of CenterSquare or its employees, CenterSquare has implemented a series of policies including, but not limited to, its Code of Ethics, which addresses avoidance of conflicts of interest and includes the firm’s personal security trading policies, which addresses personal security trading and requires the use of approved brokers, Trade Allocation/Aggregation Policy, which addresses fairness of trade allocation to client accounts, and the Proxy and Trade Error Policies which are designed to prevent and detect conflicts when they occur. CenterSquare reasonably believes that these and other policies combined with the periodic review and testing performed by its compliance professionals adequately protects the interest of its clients. A portfolio manager may also face other potential conflicts of interest in managing the Fund, and the description above is not a complete description of every conflict of interest that could be deemed to exist in managing both the Fund and the other accounts listed above. |
Columbia Management: Like other investment professionals with multiple clients, a Fund’s portfolio manager(s) may face certain potential conflicts of interest in connection with managing both the Fund and other accounts at the same time. The Investment Manager and the Funds have adopted compliance policies and procedures that attempt to address certain of the potential conflicts that portfolio managers face in this regard. Certain of these conflicts of interest are summarized below. | |
The management of accounts with different advisory fee rates and/or fee structures, including accounts that pay advisory fees based on account performance (performance fee accounts), may raise potential conflicts of interest for a portfolio manager by creating an incentive to favor higher fee accounts. | |
Potential conflicts of interest also may arise when a portfolio manager has personal investments in other accounts that may create an incentive to favor those accounts. As a general matter and subject to the Investment Manager’s Code of Ethics and certain limited exceptions, the Investment Manager’s investment professionals do not have the opportunity to invest in client accounts, other than the funds. | |
A portfolio manager who is responsible for managing multiple funds and/or accounts may devote unequal time and attention to the management of those Funds and/or accounts. The effects of this potential conflict may be more pronounced where Funds and/or accounts managed by a particular portfolio manager have different investment strategies. | |
A portfolio manager may be able to select or influence the selection of the broker/dealers that are used to execute securities transactions for the Funds. A portfolio manager’s decision as to the selection of broker/dealers could produce disproportionate costs and benefits among the Funds and the other accounts the portfolio manager manages. | |
A potential conflict of interest may arise when a portfolio manager buys or sells the same securities for a Fund and other accounts. On occasions when a portfolio manager considers the purchase or sale of a security to be in the best interests of a Fund as well as other accounts, the Investment Manager’s trading desk may, to the extent consistent with applicable laws and regulations, aggregate the securities to be sold or bought in order to obtain the best execution and lower brokerage commissions, if any. Aggregation of trades may create the potential for unfairness to a Fund or another account if a portfolio |
Statement of Additional Information – May 1, 2020 | 113 |
manager favors one account over another in allocating the securities bought or sold. The Investment Manager and its Participating Affiliates (including Threadneedle) may coordinate their trading operations for certain types of securities and transactions pursuant to personnel-sharing agreements or similar intercompany arrangements. However, typically the Investment Manager does not coordinate trading activities with a Participating Affiliate with respect to accounts of that Participating Affiliate unless such Participating Affiliate is also providing trading services for accounts managed by the Investment Manager. Similarly, a Participating Affiliate typically does not coordinate trading activities with the Investment Manager with respect to accounts of the Investment Manager unless the Investment Manager is also providing trading services for accounts managed by such Participating Affiliate. As a result, it is possible that the Investment Manager and its Participating Affiliates may trade in the same instruments at the same time, in the same or opposite direction or in different sequence, which could negatively impact the prices paid by the Fund on such instruments. Additionally, in circumstances where trading services are being provided on a coordinated basis for the Investment Manager’s accounts (including the Funds) and the accounts of one or more Participating Affiliates in accordance with applicable law, it is possible that the allocation opportunities available to the Funds may be decreased, especially for less actively traded securities, or orders may take longer to execute, which may negatively impact Fund performance. | |
“Cross trades,” in which a portfolio manager sells a particular security held by a Fund to another account (potentially saving transaction costs for both accounts), could involve a potential conflict of interest if, for example, a portfolio manager is permitted to sell a security from one account to another account at a higher price than an independent third party would pay. The Investment Manager and the Funds have adopted compliance procedures that provide that any transactions between a Fund and another account managed by the Investment Manager are to be made at a current market price, consistent with applicable laws and regulations. | |
Another potential conflict of interest may arise based on the different investment objectives and strategies of a Fund and other accounts managed by its portfolio manager(s). Depending on another account’s objectives and other factors, a portfolio manager may give advice to and make decisions for a Fund that may differ from advice given, or the timing or nature of decisions made, with respect to another account. A portfolio manager’s investment decisions are the product of many factors in addition to basic suitability for the particular account involved. Thus, a portfolio manager may buy or sell a particular security for certain accounts, and not for a Fund, even though it could have been bought or sold for the Fund at the same time. A portfolio manager also may buy a particular security for one or more accounts when one or more other accounts are selling the security (including short sales). There may be circumstances when a portfolio manager’s purchases or sales of portfolio securities for one or more accounts may have an adverse effect on other accounts, including the Funds. | |
To the extent a Fund invests in underlying funds, a portfolio manager will be subject to the potential conflicts of interest described in Potential Conflicts of Interest – Columbia Management – FOF (Fund-of-Funds) below. | |
A Fund’s portfolio manager(s) also may have other potential conflicts of interest in managing the Fund, and the description above is not a complete description of every conflict that could exist in managing the Fund and other accounts. Many of the potential conflicts of interest to which the Investment Manager’s portfolio managers are subject are essentially the same or similar to the potential conflicts of interest related to the investment management activities of the Investment Manager and its affiliates. |
Columbia Management – FoF (Fund-of-Funds): Management of funds-of-funds differs from that of the other Funds. The portfolio management process is set forth generally below and in more detail in the Funds’ prospectus. | |
Portfolio managers of the fund-of-funds may be involved in determining each funds-of-fund’s allocation among the three main asset classes (equity, fixed income and cash) and the allocation among investment categories within each asset class, as well as each funds-of-fund’s allocation among the underlying funds. |
■ | Because of the structure of the funds-of-funds, the potential conflicts of interest for the portfolio managers may be different than the potential conflicts of interest for portfolio managers who manage other Funds. |
■ | The Investment Manager and its affiliates may receive higher compensation as a result of allocations to underlying funds with higher fees. |
Statement of Additional Information – May 1, 2020 | 114 |
Statement of Additional Information – May 1, 2020 | 115 |
■ | Time Management. The management of the Fund and other Accounts may result in a portfolio manager devoting unequal time and attention to the management of the Fund and/or Accounts. DFA seeks to manage such competing interests for the time and attention of portfolio managers by having portfolio managers focus on a particular investment discipline. Accounts managed by a portfolio manager within an investment discipline may be managed using the same investment approach. |
■ | Investment Opportunities. It is possible that at times identical securities will be held by the Fund and one or more Accounts. However, positions in the same security may vary and the length of time that the Fund may hold investments in the same security may likewise vary. If a portfolio manager identifies a limited investment opportunity that may be suitable for the Fund and one or more Accounts, the Fund may not be able to take full advantage of that opportunity due to an allocation of filled purchase or sale orders across all eligible Accounts. To address these situations, DFA has adopted procedures for allocating portfolio transactions across multiple Accounts. |
■ | Broker Selection. With respect to securities transactions for the Fund, DFA determines which broker to use to execute each order, consistent with its duty to seek best execution of the transaction. However, with respect to certain Accounts (such as separately managed accounts), DFA may be limited by the client with respect to the selection of brokers or may be instructed to direct trades through a particular broker. In these cases, DFA or its affiliates may place separate, non-simultaneous, transactions for the Fund and another Account that may temporarily affect the market price of the security or the execution of the transaction, or both, to the detriment of the Fund or the Account. |
■ | Performance-Based Fees. For some Accounts, DFA may be compensated based on the profitability of the Account, such as by a performance-based management fee. These incentive compensation structures may create a conflict of interest for DFA with regard to Accounts where DFA is paid based on a percentage of assets because the portfolio manager may have an incentive to allocate securities preferentially to the Accounts where DFA might share in investment gains. |
■ | Investment in an Account. A portfolio manager or his/her relatives may invest in an Account that he or she manages and a conflict may arise where he or she may therefore have an incentive to treat the Account in which the portfolio manager or his/her relatives invest preferentially as compared to other Accounts for which he or she has portfolio management responsibilities. |
Statement of Additional Information – May 1, 2020 | 116 |
Statement of Additional Information – May 1, 2020 | 117 |
Los Angeles Capital: Los Angeles Capital has implemented policies and procedures, including brokerage and trade allocation policies and procedures, which the firm believes are reasonably designed to address the potential for conflicts of interest associated with managing portfolios for multiple clients and that seek to treat all clients fairly and equally over time and to mitigate conflicts among accounts. Client accounts are managed independent of one another in accordance with client specific mandates, restrictions, and instructions as outlined in the investment management agreement, and such restrictions and instructions are monitored for compliance with the client’s investment guidelines. This side-by-side management can result in investment positions or actions taken for one client account that differ from those taken in another client account. Accordingly, one client account can engage in short sales of or take a short position in an investment that at the same time is owned or being purchased long by another client account. These positions and actions can adversely affect or benefit different clients at different times. |
The firm manages client accounts have different investment strategies, objectives, restrictions, constraints, launch dates, and overlapping benchmark constituents. Given these customizations and differences, it is possible that Los Angeles Capital may |
Statement of Additional Information – May 1, 2020 | 118 |
The decision as to which accounts participate in an investment opportunity will take into account, among other things, the model’s outlook on the account’s strategy, the account’s investment guidelines, and risk metrics. Furthermore, global accounts’ orders are sent to the market simultaneously subject to prevailing market conditions, client flows, and liquidity. Emerging markets account orders are aggregated during account rebalances, but the firm is not required to do so. |
Los Angeles Capital’s proprietary optimization-based technology for trading client portfolios complements the firm’s approach to stock selection and uses real-time market prices to parse the master (“parent”) order lists into a sub-list or “child” order lists, for execution by agency brokers. For accounts traded using the trade optimization technology, real-time market prices are the primary creation determinant in each child order. Therefore, names traded for one account (or group of accounts) may result in different execution prices than a name traded for another account (or group of accounts). The firm’s trade optimization technology is primarily used for U.S. market accounts. As the firm’s trade optimization trading technology is dependent upon robust and consistent market data, Los Angeles Capital does not currently utilize this technology in Developed Asia and Emerging Markets. |
While each client account is managed individually, Los Angeles Capital may, at any given time, purchase and/or sell the same security in a block that is allocated among multiple accounts. There are a number of variables that can influence a decision to aggregate purchases or sales into a block, including but not limited to, order size, liquidity, client trading directives, regulatory limitations, round lot requirements, and cash flows. The firm allocates trades that are submitted in a block prior to placing the trade with the broker. When there is decision making on whether to include or exclude certain accounts from a block transaction, there is always the potential for conflicts of interest. Furthermore, the effect of trade aggregation may work on some occasions to the account’s disadvantage. Los Angeles Capital’s policies and procedures in allocating trades are structured to treat all clients fairly. Los Angeles Capital is not required to aggregate any particular trade. For example, an account with directed brokerage may not participate in certain block trades. |
Los Angeles Capital’s portfolio managers manage accounts that are charged a performance-based fee alongside accounts in the same strategy with asset-based fee schedules. While performance-based fee arrangements may be viewed as creating an incentive to favor certain accounts over others in the allocation of investment opportunities, Los Angeles Capital has designed and implemented procedures to ensure that all clients are treated fairly and equally, and to prevent conflicts from influencing the allocation of investment opportunities. Management and performance fees inure to the benefit of the firm as a whole and not to specific individuals or groups of individuals. Further, Los Angeles Capital employs a quantitative investment process which utilizes the firm’s proprietary investment model technology to identify securities and construct portfolios. |
The firm’s strategies predominantly invest in liquid common stocks. Based on a variety of factors including the strategy, guidelines, and turnover goals, Los Angeles Capital determines the trading frequency for each account with most accounts trading at least semi-monthly and others less frequently. In a typical week, Los Angeles Capital will begin by trading its U.S. strategy accounts followed by its non-U.S. strategy accounts. An account’s rebalance cycle is dependent on the account’s strategy. Rebalances for U.S. strategy accounts are regularly rotated between traders and generally begin on the same day each week. Non-U.S. strategy account rebalances may be regularly rotated over several days. The firm’s proprietary accounts, which are invested in liquid, benchmark securities, may be traded in rotation with client accounts or on a particular day of the week depending on liquidity, size, model constraints, and resource constraints. |
Los Angeles Capital has adopted a Code of Ethics that includes procedures on ethical conduct and personal trading and requires pre-clearance authorization from both the Trading and Compliance and Regulatory Risk Departments for certain personal security transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code of Ethics, and is designed to reasonably identify and prevent conflicts of interest between the firm and its clients. |
Investment personnel of Los Angeles Capital or its affiliate may be permitted to be commercially or professionally involved with an issuer of securities. There is a potential risk that Los Angeles Capital personnel may place their own interests (resulting from outside employment/directorships) ahead of the interests of Los Angeles Capital clients. Before engaging in any outside business activity, employees must obtain approval of the CCO as well as other personnel. Any potential conflicts of interest from such involvement are monitored for compliance with Los Angeles Capital’s Code of Ethics. The Code of Ethics also governs employees giving or accepting gifts and entertainment. |
Statement of Additional Information – May 1, 2020 | 119 |
MFS: MFS seeks to identify potential conflicts of interest resulting from a portfolio manager’s management of both the Fund and other accounts, and has adopted policies and procedures designed to address such potential conflicts. | |
The management of multiple funds and accounts (including proprietary accounts) gives rise to conflicts of interest if the funds and accounts have different objectives and strategies, benchmarks, time horizons and fees as a portfolio manager must allocate his or her time and investment ideas across multiple funds and accounts. In certain instances there are securities which are suitable for the Fund’s portfolio as well as for accounts of MFS or its subsidiaries with similar investment objectives. MFS’ trade allocation policies may give rise to conflicts of interest if the Fund’s orders do not get fully executed or are delayed in getting executed due to being aggregated with those of other accounts of MFS or its subsidiaries. A portfolio manager may execute transactions for another fund or account that may adversely affect the value of the Fund’s investments. Investments selected for funds or accounts other than the Fund may outperform investments selected for the Fund. | |
When two or more clients are simultaneously engaged in the purchase or sale of the same security, the securities are allocated among clients in a manner believed by MFS to be fair and equitable to each. Allocations may be based on many factors and may not always be pro rata based on assets managed. The allocation methodology could have a detrimental effect on the price or volume of the security as far as the Fund is concerned. | |
MFS and/or a portfolio manager may have a financial incentive to allocate favorable or limited opportunity investments or structure the timing of investments to favor accounts other than the Fund, for instance, those that pay a higher advisory fee and/or have a performance adjustment and/or include an investment by the portfolio manager. |
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Scout: Scout and its affiliates may have proprietary interests in, and may manage or advise with respect to, accounts or funds (including separate accounts and other funds and collective investment vehicles) that have investment objectives similar to those of the Fund and/or that engage in transactions in the same types of securities and instruments as the Fund. |
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Scout has adopted policies and procedures to address the allocation of investment opportunities, the execution of portfolio transactions and other potential conflicts of interest that are designed to ensure that all clients are treated fair and equitably over time. Scout and its affiliates or their clients are or may be actively engaged in transactions in the same securities and instruments in which the Fund invests. Such activities could affect the prices and availability of the securities and instruments in which the Fund invests, which could have an adverse impact on the Fund’s performance. When Scout seeks to purchase or sell the same assets for their managed accounts, including the Fund, the assets actually purchased or sold may be allocated among the accounts on a basis determined in their good faith discretion to be equitable in accordance with Scout’s policies and procedures. In some cases, these transactions may adversely affect the size or price of the assets purchased or sold for the Fund. Further, transactions in investments by one or more other accounts or clients advised by Scout may have the effect of diluting or otherwise disadvantaging the values, prices or investment strategies of the Fund. This may occur when investment decisions regarding the Fund are based on research or other information that is also used to support decisions or advice for other accounts. When Scout or one of its other clients implements a portfolio decision or strategy on behalf of another account ahead of, or contemporaneously with, similar decisions or strategies for the Fund, market impact, liquidity constraints or other factors could result in the Fund receiving less favorable trading results and the costs of implementing such decisions or strategies could be increased or the Fund could otherwise be disadvantaged. Such transactions, particularly in respect of most proprietary accounts or customer accounts, may be executed independently of the Fund’s transactions and thus at prices or rates that may be more or less favorable than those obtained by the Fund. Employees of Scout, including investment personnel, may buy and sell securities for their own personal accounts that are also bought and sold for the Fund. Scout has adopted and enforces a Code of Ethics that requires employees to follow standards of conduct when conducting these personal transactions. | |
T. Rowe Price: Portfolio managers at T. Rowe Price and its affiliates may manage multiple accounts. These accounts may include, among others, mutual funds, separate accounts (assets managed on behalf of institutions such as pension funds, colleges and universities, and foundations), offshore funds and common trust funds. Portfolio managers make investment decisions for each portfolio based on the investment objectives, policies, practices, and other relevant investment considerations that the managers believe are applicable to that portfolio. Consequently, portfolio managers may purchase (or sell) securities for one portfolio and not another portfolio. T. Rowe Price and its affiliates have adopted brokerage and trade allocation policies and procedures that they believe are reasonably designed to address any potential conflicts associated with managing multiple accounts for multiple clients. Also, the portfolio managers’ compensation is determined in the same manner with respect to all portfolios managed by the portfolio manager. |
The T. Rowe Price funds may, from time to time, own shares of Morningstar, Inc. Morningstar is a provider of investment research to individual and institutional investors, and publishes ratings on mutual funds, including the T. Rowe Price funds. T. Rowe Price manages the Morningstar retirement plan and acts as subadvisor to two mutual funds offered by Morningstar. In addition, T. Rowe Price and its affiliates pay Morningstar for a variety of products and services. In addition, Morningstar may provide investment consulting and investment management services to clients of T. Rowe Price or its affiliates. |
Since the T. Rowe Price funds and other accounts have different investment objectives or strategies, potential conflicts of interest may arise in executing investment decisions or trades among client accounts. For example, if T. Rowe Price purchases a security for one account and sells the same security short for another account, such a trading pattern could disadvantage either the account that is long or short. It is possible that short sale activity could adversely affect the market value of long positions in one or more T. Rowe Price funds and other accounts (and vice versa) and create potential trading conflicts, such as when long and short positions are being executed at the same time. To mitigate these potential conflicts of interest, T. Rowe Price has implemented policies and procedures requiring trading and investment decisions to be made in accordance with T. Rowe Price’s fiduciary duties to all accounts, including the T. Rowe Price funds. Pursuant to these policies, portfolio managers are generally prohibited from managing multiple strategies where they hold the same security long in one strategy and short in another, except in certain circumstances, including where an investment oversight committee has specifically reviewed and approved the holdings or strategy. Additionally, T. Rowe Price has implemented policies and procedures that it believes are reasonably designed to ensure the fair and equitable allocation of trades, both long and short, to minimize the impact of trading activity across client accounts. T. Rowe Price monitors short sales to determine whether its procedures are working as intended and that such short sale activity is not materially impacting our trade executions and long positions for other clients. | |
TCW: TCW has policies and controls to avoid and/or mitigate conflicts of interest across its businesses. The policies and procedures in TCW’s Code of Ethics (the “Code”) serve to address or mitigate both conflicts of interest and the appearance of any conflict of interest. The Code contains several restrictions and procedures designed to eliminate conflicts of interest relating to personal investment transactions, including (i) reporting account openings, changes, or closings (including accounts in which an Access Person has a "beneficial interest"), (ii) pre-clearance of non-exempt personal investment transactions (make a personal trade request for Securities) and (iii) the completion of timely required reporting (Initial Holdings Report, Quarterly Transactions Report, Annual Holdings Report and Annual Certificate of Compliance). |
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In addition, the Code addresses potential conflicts of interest through its policies on insider trading, anti-corruption, an employee’s outside business activities, political activities and contributions, confidentiality and whistleblower provisions. | |
Conflicts of interest may also arise in the management of accounts and investment vehicles. These conflicts may raise questions that would allow TCW to allocate investment opportunities in a way that favors certain accounts or investment vehicles over other accounts or investment vehicles, or incentivize a TCW portfolio manager to receive greater compensation with regard to the management of certain account or investment vehicles. TCW may give advice or take action with certain accounts or investment vehicles that could differ from the advice given or action taken on other accounts or investment vehicles. When an investment opportunity is suitable for more than one account or investment vehicle, such investments will be allocated in a manner that is fair and equitable under the circumstances to all TCW clients. As such, TCW has adopted compliance policies and procedures in its Portfolio Management Policy that helps to identify a conflict of interest and then specifies how a conflict of interest is managed. TCW’s Trading and Brokerage Policy also discusses the process of timing and method of allocations, and addresses how the firm handles affiliate transactions. | |
The respective Equity and Fixed Income Trading and Allocation Committees review trading activities on behalf of client accounts, including the allocation of investment opportunities and address any issues with regard to side-by-side management in order to ensure that all of TCW’s clients are treated on a fair and equitable basis. Further, the Portfolio Analytics Committee reviews TCW’s investment strategies, evaluates various analytics to facilitate risk assessment, changes to performance composites and benchmarks and monitors the implementation and maintenance of the Global Investment Performance Standards or GIPS® compliance. | |
TCW’s approach to handling conflicts of interest is multi-layered starting with its policies and procedures, reporting and pre-clearance processes and oversight by various committees. |
Threadneedle: Threadneedle portfolio managers may manage one or more mutual funds as well as other types of accounts, including proprietary accounts, separate accounts for institutions, and other pooled investment vehicles. Portfolio managers make investment decisions for an account or portfolio based on its investment objectives and policies, and other relevant investment considerations. A portfolio manager may manage a separate account or other pooled investment vehicle whose fees may be materially greater than the management fees paid by the Fund and may include a performance-based fee. Management of multiple funds and accounts may create potential conflicts of interest relating to the allocation of investment opportunities, and the aggregation and allocation of trades. In addition, a portfolio manager’s responsibilities at Threadneedle include working as a securities analyst. This dual role may give rise to conflicts with respect to making investment decisions for accounts that he/she manages versus communicating his/her analyses to other portfolio managers concerning securities that he/she follows as an analyst. | |
Threadneedle has a fiduciary responsibility to all of the clients for which it manages accounts. Threadneedle seeks to provide best execution of all securities transactions and to aggregate securities transactions and then allocate securities to client accounts in a fair and timely manner. Threadneedle has developed policies and procedures, including brokerage and trade allocation policies and procedures, designed to mitigate and manage the potential conflicts of interest that may arise from the management of multiple types of accounts for multiple clients. | |
Victory Capital: Victory Capital states that its portfolio managers are often responsible for managing one or more mutual funds as well as other accounts, such as separate accounts, and other pooled investment vehicles, such as collective trust funds or unregistered hedge funds. A portfolio manager may manage other accounts which have materially higher fee arrangements than the Fund and may, in the future, manage other accounts which have a performance-based fee. A portfolio manager also may make personal investments in accounts they manage or support. The side-by-side management of the Fund along with other accounts may raise potential conflicts of interest by incenting a portfolio manager to direct a disproportionate amount of: (1) their attention; (2) limited investment opportunities, such as less liquid securities or initial public offerings; and/or (3) desirable trade allocations, to such other accounts. In addition, certain trading practices, such as cross-trading between the Fund and another account, raise conflict of interest issues. Victory Capital has adopted numerous compliance policies and procedures, including a Code of Ethics, and brokerage and trade allocation policies and procedures, which seek to address the conflicts associated with managing multiple accounts for multiple clients. In addition, Victory Capital has a designated Chief Compliance Officer (selected in accordance with the federal securities laws) and compliance staff whose activities are focused on monitoring the activities of Victory Capital's investment franchises and employees in order to detect and address potential and actual conflicts of interest. However, there can be no assurance that Victory Capital's compliance program will achieve its intended result. | |
WellsCap: WellsCap’s Portfolio Managers often provide investment management for separate accounts advised in the same or similar investment style as that provided to mutual funds. While management of multiple accounts could potentially lead to conflicts of interest over various issues such as trade allocation, fee disparities and research acquisition, WellsCap has implemented policies and procedures for the express purpose of ensuring that clients are treated fairly and that potential conflicts of interest are minimized. |
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The Portfolio Managers face inherent conflicts of interest in their day-to-day management of the Funds and other accounts because the Funds may have different investment objectives, strategies and risk profiles than the other accounts managed by the Portfolio Managers. For instance, to the extent that the Portfolio Managers manage accounts with different investment strategies than the Funds, they may from time to time be inclined to purchase securities, including initial public offerings, for one account but not for a Fund. Additionally, some of the accounts managed by the Portfolio Managers may have different fee structures, including performance fees, which are or have the potential to be higher or lower, in some cases significantly higher or lower, than the fees paid by the Funds. The differences in fee structures may provide an incentive to the Portfolio Managers to allocate more favorable trades to the higher-paying accounts. | |
To minimize the effects of these inherent conflicts of interest, WellsCap has adopted and implemented policies and procedures, including brokerage and trade allocation policies and procedures, that they believe address the potential conflicts associated with managing portfolios for multiple clients and are designed to ensure that all clients are treated fairly and equitably. Accordingly, security block purchases are allocated to all accounts with similar objectives in a fair and equitable manner. Furthermore, WellsCap has adopted a Code of Ethics under Rule 17j-1 under the 1940 Act and Rule 204A-1 under the Investment Advisers Act of 1940 (the “Advisers Act”) to address potential conflicts associated with managing the Funds and any personal accounts the Portfolio Managers may maintain. | |
Westfield: The simultaneous management of multiple accounts by our investment professionals creates a possible conflict of interest as they must allocate their time and investment ideas across multiple accounts. This may result in the Investment Committee or portfolio managers allocating unequal attention and time to the management of each client account as each has different objectives, benchmarks, investment restrictions and fees. For most client accounts, investment decisions are made at the Investment Committee level. Once an idea has been approved, it is implemented across all eligible and participating accounts within the strategy. | |
Although the Investment Committee collectively acts as portfolio manager on most client accounts, there are some client accounts that are managed by a portfolio manager who also serves as a member of the Investment Committee. This can create a conflict of interest because investment decisions for these individually managed accounts do not require approval by the Investment Committee; thus, there is an opportunity for individually managed client accounts to trade in a security ahead of Investment Committee managed client accounts. Trade orders for individually managed accounts must be communicated to the Investment Committee. Additionally, the Compliance team performs periodic reviews of such accounts to ensure procedures have been followed. | |
Westfield has clients with performance-based fee arrangements. A conflict of interest can arise between those portfolios that incorporate a performance fee and those that do not. When the same securities are recommended for both types of accounts, it is Westfield’s policy to allocate investments, on a pro-rata basis, to all participating and eligible accounts, regardless of the account’s fee structure. Our Operations team performs ongoing reviews of each product’s model portfolio versus each client account. Discrepancies are researched, and exceptions are documented. | |
In placing each transaction for a client’s account, Westfield seeks best execution of that transaction except in cases where Westfield does not have the authority to select the broker or dealer, as stipulated by the client. We attempt to bundle directed brokerage accounts with non-directed accounts, and then utilize step-out trades to satisfy the directed arrangements. Clients who do not allow step-out trades generally will be executed after non-directed accounts. |
Because of our interest in receiving third party research services, there may be an incentive for Westfield to select a broker or dealer based on such interest rather than the clients’ interest in receiving most favorable execution. To mitigate the conflict that Westfield may have an incentive beyond best execution to utilize a particular broker, broker and research votes are conducted and reviewed on a quarterly basis. These votes provide the opportunity to recognize the unique research efforts of a wide variety of firms, as well as the opportunity to compare aggregate commission dollars with a particular broker to ensure appropriate correlation. Westfield’s Best Execution Committee also reviews transaction cost analysis data quarterly to monitor trading and commission activity. | |
Some Westfield clients have elected to retain certain brokerage firms as consultants or to invest their assets through a broker-sponsored wrap program for which Westfield acts as a manager. Several of these firms are on our approved broker list. Since Westfield may gain new clients through such relationships and will interact closely with such firms to service the client, there may be an incentive for Westfield to select a broker or dealer based on such interest rather than the clients’ interest. To help ensure independence in the brokerage selection process, brokerage selection is handled by our Traders, while client relationships are managed by our Marketing/Client Service team. |
Personal accounts may give rise to conflicts of interest. Westfield and its employees will, from time to time, for their own investment accounts, purchase, sell, hold or own securities or other assets which may be recommended for purchase, sale or ownership for one or more clients. Westfield has a Code of Ethics which regulates trading in such accounts; requirements include regular reporting and preclearance of transactions. Compliance reviews personal trading activity regularly. |
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Westfield serves as manager to the General Partners of private funds, for which we also provide investment advisory services. Westfield and its employees have also invested their own funds in such vehicles and other investment strategies that are advised by the firm. Allowing such investments and having a financial interest in the private funds can create an incentive for the firm to favor these accounts because our financial interests are more directly tied to the performance of such accounts. To help ensure all clients are treated equitably and fairly, Westfield allocates investment opportunities on a pro-rata basis. Compliance conducts periodic reviews of client accounts to ensure procedures have been followed. |
In addition to a base salary and a performance-based bonus award, Westfield’s Marketing and Client Service team’s compensation is based on a percentage of annual revenue generated by new separate accounts and/or significant contributions to existing client accounts but excludes any sub-advised or advised mutual funds. This incentive poses a conflict in that members of the team could encourage investment in a product(s) that may not be suitable. To mitigate such risk, team members are not incentivized to sell one product versus another. Nor do they have specific sales targets. Further, Westfield’s new account process includes a review of client contracts and investment policy statements to ensure the recommended product is suitable prior to funding. Lastly, all incentive compensation is reviewed and approved by the COO and CFO. |
William Blair: Since William Blair’s portfolio managers manage other accounts in addition to the Fund, conflicts of interest may arise in connection with the portfolio managers’ management of the Fund’s investments on the one hand and the investments of such other accounts on the other hand. The conflicts of interest that arise in managing multiple accounts include, for example, conflicts due to investment strategies, objectives, restrictions, time horizon and fees. William Blair has adopted policies and procedures designed to address such conflicts, including, among others, policies and procedures relating to allocation of investment opportunities, soft dollars and aggregation of trades. William Blair seeks to conduct itself in a manner it considers to be the most fair and consistent with its fiduciary obligations to clients, including the Fund, and make investment decisions based on an account’s investment objectives, restrictions, permitted investment techniques, available cash and other relevant considerations. |
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AQR: The compensation for each of the portfolio managers that is a Principal of AQR is in the form of distributions based on the net income generated by AQR and each Principal’s relative ownership in AQR. Net income distributions are a function of assets under management and performance of the funds and accounts managed by AQR. A Principal’s relative ownership in AQR is based on cumulative research, leadership and other contributions to AQR. There is no direct linkage between assets under management, performance and compensation. However, there is an indirect linkage in that superior performance tends to attract assets and thus increase revenues. Each portfolio manager is also eligible to participate in AQR’s 401(k) retirement plan which is offered to all employees of AQR. | |
BlackRock: BlackRock’s financial arrangements with its portfolio managers, its competitive compensation and its career path emphasis at all levels reflect the value senior management places on key resources. Compensation may include a variety of components and may vary from year to year based on a number of factors. The principal components of compensation include a base salary, a performance-based discretionary bonus, participation in various benefits programs and one or more of the incentive compensation programs established by BlackRock. | |
Base Compensation. Generally, portfolio managers receive base compensation based on their position with the firm. |
Portfolio Manager | Benchmark |
Christopher Allen | Varied Euro-Based Benchmarks |
Akiva Dickstein
Emanuella Enenajor |
A combination of market-based indices (e.g. Bloomberg Barclays US Aggregate Index, Bloomberg Barclays US Universal Index and Bloomberg Barclays Intermediate Aggregate Index), certain customized indices and certain fund industry peer groups. |
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BMO: Compensation for BMO’s portfolio managers consists of base salary, discretionary performance bonuses, and other benefits. Base salaries are reviewed on an annual basis to ensure alignment with the external market. Discretionary performance bonuses vary according to business and individual performance and are provided in a combination of cash and deferred equity-based awards for employees at higher levels of compensation. Portfolio managers also may have a long-term incentive program consisting of restricted share units or other units linked to the performance of BMO. |
CenterSquare: CenterSquare’s compensation structure is comprised of base pay and annual incentive compensation. Individuals’ packages are designed with the appropriate component combinations to match specific positions. |
■ | Base pay: salary is competitive and base pay levels link pay with performance and reflect the market value of the position, individual performance and company business results. |
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■ | Annual Cash Bonus: the annual cash bonus plan is based on individual performance, including individual contribution to meeting business unit goals, career development goals and adherence to corporate values. The annual cash bonus plan pool is computed based on the profitability of the firm. |
■ | Equity grant awards: management has reserved equity grant awards for employees based on a number of factors including exemplary performance and contributions to the company. |
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■ | Base salary. Each portfolio manager is paid a base salary. DFA considers the factors described above to determine each portfolio manager’s base salary. |
■ | Semi-Annual Bonus. Each portfolio manager may receive a semi-annual bonus. The amount of the bonus paid to each portfolio manager is based upon the factors described above. |
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Loomis Sayles: Loomis Sayles believes that portfolio manager compensation should be driven primarily by the delivery of consistent and superior long-term performance for its clients. |
Mr. Hamzaogullari’s compensation has four components: a competitive base salary, an annual incentive bonus driven by investment performance, participation in long-term incentive plans (annual and post-retirement payouts), and a revenue sharing bonus if certain revenue thresholds and performance hurdles are met. Maximum variable compensation potential is a multiple of base salary and reflects performance achievements relative to peers with similar disciplines. The performance review considers the asset class, manager experience, and maturity of the product. The incentive compensation is based on trailing strategy performance and is weighted at one third for the three-year period, one third for the five-year period and one third for the ten-year period. He is compensated according to the overall performance of the strategy and a portion of the revenue is delivered in compensation if certain revenue thresholds and performance hurdles are met. He also receives performance based compensation as portfolio manager for a private investment fund. The firm’s Chief Investment Officer and senior management review the components annually. |
In addition, Mr. Hamzaogullari participates in the Loomis Sayles profit sharing plan, in which Loomis Sayles makes a contribution to the retirement plan of each employee based on a percentage of base salary (up to a maximum amount). He may also participate in the Loomis Sayles deferred compensation plan which requires all employees to defer 50% of their annual bonus if in excess of a certain dollar amount, except for those employees who will be age 61 or older on the date the bonus is awarded. These amounts are deferred over a two year period with 50% being paid out one year from the bonus anniversary date and the second 50% being paid out two years from the bonus anniversary date. These deferrals are deposited into an investment account on the employee's behalf, but the employee must be here on the vesting dates in order to receive the deferred bonus. |
Los Angeles Capital: Los Angeles Capital’s portfolio managers participate in a competitive compensation program that is aimed at attracting and retaining talented employees with an emphasis on disciplined risk management, ethics and compliance-centered behavior. No component of Los Angeles Capital’s compensation policy or payment scheme is tied directly to the performance of one or more client portfolios or funds. |
Each of Los Angeles Capital’s portfolio managers receives a base salary fixed from year to year. In addition, the portfolio managers participate in Los Angeles Capital’s profit sharing plan. The aggregate amount of the contribution to Los Angeles Capital’s profit sharing plan is based on overall firm profitability with amounts paid to individual employees based on their relative overall compensation. Each of the portfolio managers also are shareholders of Los Angeles Capital and receive compensation based upon the firm’s overall profits. Certain portfolio managers are also eligible to receive a discretionary bonus from Los Angeles Capital. | |
MFS: MFS’ philosophy is to align portfolio manager compensation with the goal to provide shareholders with long-term value through a collaborative investment process. Therefore, MFS uses long-term investment performance as well as contribution to the overall investment process and collaborative culture as key factors in determining portfolio manager compensation. In addition, MFS seeks to maintain total compensation programs that are competitive in the asset management industry in each geographic market where it has employees. MFS uses competitive compensation data to ensure that compensation practices are aligned with its goals of attracting, retaining, and motivating the highest-quality professionals. |
MFS reviews portfolio manager compensation annually. In determining portfolio manager compensation, MFS uses quantitative means and qualitative means to help ensure a sustainable investment process. As of December 31, 2019, portfolio manager total cash compensation is a combination of base salary and performance bonus: |
Base Salary – Base salary generally represents a smaller percentage of portfolio manager total cash compensation than performance bonus. |
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Performance Bonus – Generally, the performance bonus represents more than a majority of portfolio manager total cash compensation. | |
The performance bonus is based on a combination of quantitative and qualitative factors, generally with more weight given to the former and less weight given to the latter. |
The quantitative portion is primarily based on the pre-tax performance of accounts managed by the portfolio manager over a range of fixed-length time periods, intended to provide the ability to assess performance over time periods consistent with a full market cycle and a strategy's investment horizon. The fixed-length time periods include the portfolio manager's full tenure on each fund and, when available, ten-, five-, and three-year periods. For portfolio managers who have served for less than three years, shorter-term periods, including the one-year period, will also be considered, as will performance in previous roles, if any, held at the firm. Emphasis is generally placed on longer performance periods when multiple performance periods are available. Performance is evaluated across the full set of strategies and portfolios managed by a given portfolio manager, relative to appropriate peer group universes and/or representative indices (“benchmarks”). As of December 31, 2019, the Russell 1000® Value Index was used to measure the performance of Nevin Chitkara, Katherine Cannan and Steve Gorham for the VP – MFS Value Fund. |
Benchmarks may include versions and components of indices, custom indices, and linked indices that combine performance of different indices for different portions of the time period, where appropriate. | |
The qualitative portion is based on the results of an annual internal peer review process (where portfolio managers are evaluated by other portfolio managers, analysts, and traders) and management’s assessment of overall portfolio manager contribution to the MFS investment process and the client experience (distinct from fund and other account performance). | |
The performance bonus is generally a combination of cash and a deferred cash award. A deferred cash award is issued for a cash value and becomes payable over a three-year vesting period if the portfolio manager remains in the continuous employ of MFS or its affiliates. During the vesting period, the value of the unfunded deferred cash award will fluctuate as though the portfolio manager had invested the cash value of the award in an MFS Fund(s) selected by the portfolio manager. | |
MFS Equity Plan – Portfolio managers also typically benefit from the opportunity to participate in the MFS Equity Plan. Equity interests are awarded by management, on a discretionary basis, taking into account tenure at MFS, contribution to the investment process, and other factors. | |
Finally, portfolio managers also participate in benefit plans (including a defined contribution plan and health and other insurance plans) and programs available generally to other employees of MFS. The percentage such benefits represent of any portfolio manager’s compensation depends upon the length of the individual’s tenure at MFS and salary level, as well as other factors. | |
MSIM: Morgan Stanley’s compensation structure is based on a total reward system of base salary and incentive compensation, which is paid either in the form of cash bonus, or for employees meeting the specified deferred compensation eligibility threshold, partially as a cash bonus and partially as mandatory deferred compensation. Deferred compensation granted to Investment Management employees are generally granted as a mix of deferred cash awards under the Investment Management Alignment Plan (IMAP and equity-based awards in the form of stock units. The portion of incentive compensation granted in the form of a deferred compensation award and the terms of such awards are determined annually by the Compensation, Management Development and Succession Committee of the Morgan Stanley Board of Directors. |
Base salary compensation. Generally, portfolio managers receive base salary compensation based on the level of their position with MSIM. |
Incentive compensation. In addition to base compensation, portfolio managers may receive discretionary year-end compensation. | |
Incentive compensation may include: |
■ | Cash Bonus. |
■ | Deferred Compensation: |
■ | A mandatory program that defers a portion of incentive compensation into restricted stock units or other awards based on Morgan Stanley common stock or other plans that are subject to vesting and other conditions. |
■ | IMAP is a cash-based deferred compensation plan designed to increase the alignment of participants’ interests with the interests of the MSIM’s clients. For eligible employees, a portion of their deferred compensation is mandatorily deferred into IMAP on an annual basis. Awards granted under IMAP are notionally invested in referenced funds |
Statement of Additional Information – May 1, 2020 | 133 |
available pursuant to the plan, which are funds advised by Investment Management. Portfolio managers are required to notionally invest a minimum of 25% of their account balance in the designated funds that they manage and are included in the IMAP notional investment fund menu. | |
■ | Deferred compensation awards are typically subject to vesting over a multi-year period and are subject to cancellation through the payment date for competition, cause (i.e., any act or omission that constitutes a breach of obligation to the Company, including failure to comply with internal compliance, ethics or risk management standards, and failure or refusal to perform duties satisfactorily, including supervisory and management duties), disclosure of proprietary information, and solicitation of employees or clients. Awards are also subject to clawback through the payment date if an employee’s act or omission (including with respect to direct supervisory responsibilities) causes a restatement of the Firm’s consolidated financial results, constitutes a violation of the Firm’s global risk management principles, policies and standards, or causes a loss of revenue associated with a position on which the employee was paid and the employee operated outside of internal control policies. |
■ | Revenue and profitability of the business and/or each fund/accounts managed by the portfolio manager |
■ | Revenue and profitability of the Firm |
■ | Return on equity and risk factors of both the business units and Morgan Stanley |
■ | Assets managed by the portfolio manager |
■ | External market conditions |
■ | New business development and business sustainability |
■ | Contribution to client objectives |
■ | The pre-tax investment performance of the funds/accounts managed by the portfolio manager (which may, in certain cases, be measured against the applicable benchmark(s) and/or peer group(s) over one, three and five-year periods. |
■ | Individual contribution and performance |
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Threadneedle: Direct compensation is typically comprised of a base salary, a fixed role-based allowance paid monthly alongside salary and an annual incentive award that is paid either in the form of a cash bonus if the size of the award is under a specified threshold or, if the size of the award is over a specified threshold, the award is paid in a combination of a cash bonus, an equity incentive award, and fund-linked deferred compensation compliant with European regulatory requirements in its structure and delivery vehicles. Equity incentive awards are made in the form of Ameriprise Financial |
Statement of Additional Information – May 1, 2020 | 136 |
restricted stock, or for senior employees outside our fund management teams both Ameriprise Financial restricted stock and stock options. The investment return credited on deferred compensation is based on the performance of specified Threadneedle funds, in most cases including the funds the portfolio manager manages. | |
Base salary is typically determined based on market data relevant to the employee’s position, as well as other factors including internal equity. Base salaries are reviewed annually, and increases are typically given as promotional increases, internal equity adjustments, or market adjustments. | |
Annual incentive awards and pool funding are variable and are designed to reward: |
■ | Investment performance, both at the individual and team levels |
■ | Client requirements, in particular the alignment with clients through a mandatory deferral into the company’s own products, compliant with local regulation in particular the UCITS V requirements |
■ | Team cooperation and values |
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William Blair: The compensation of William Blair’s portfolio managers is based on the firm’s mission: “to achieve success for its clients.” Messrs. Fennell and McAtamney are partners of William Blair, and as of December 31, 2019, compensation for partners of William Blair consists of a fixed base salary, a share of the firm’s profits and, in some instances, a discretionary bonus. The discretionary bonus as well as any potential changes to the partners’ ownership stakes are determined by the head of William Blair’s Investment Management Department, subject to the approval of William Blair’s |
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Executive Committee and are based entirely on a qualitative assessment rather than a formula. The discretionary bonus rewards the specific accomplishments in the prior year, including short-term and long-term investment performance, quality of research ideas, and other contributions to William Blair and its clients. Changes in ownership stake are based on an individual’s sustained, multi-year contribution to long-term investment performance, and to William Blair’s revenue, profitability, intellectual capital and brand reputation. The compensation process is a subjective one that takes into account the factors described above. Portfolio managers do not receive any direct compensation based upon the performance of any individual client account and no indices are used to measure performance. In addition, there is no particular weighting or formula for evaluating the factors. |
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Share Class | Distribution Fee | Service Fee | Combined Total |
Class 1 | None | None | None |
Class 2 | Up to 0.25% | 0.00% | Up to 0.25% |
Class 3 | Up to 0.125% | 0.00% | Up to 0.125% |
Class 4 | Up to 0.25% | 0.00% | Up to 0.25% |
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Fund | Class 1 | Class 2 | Class 3 | Class 4 |
VP – Mid Cap Growth Fund | N/A | $61,857 | $325,988 | N/A |
VP – Moderate Portfolio | N/A | 19,598,998 | N/A | $23,043,761 |
VP – Moderately Aggressive Portfolio | N/A | 10,503,229 | N/A | 9,148,336 |
VP – Moderately Conservative Portfolio | N/A | 3,490,542 | N/A | 3,973,353 |
VP – Morgan Stanley Advantage Fund | N/A | 44,373 | N/A | N/A |
VP – MV Moderate Growth Fund | N/A | 36,755,431 | N/A | N/A |
VP – Overseas Core Fund | N/A | 140,504 | 303,677 | N/A |
VP – Partners Core Bond Fund | N/A | 25,629 | N/A | N/A |
VP – Partners Core Equity Fund | N/A | 25,998 | 41,091 | N/A |
VP – Partners International Core Equity Fund | N/A | 19,314 | N/A | N/A |
VP – Partners International Growth Fund | N/A | 82,433 | N/A | N/A |
VP – Partners International Value Fund | N/A | 54,655 | N/A | N/A |
VP – Partners Small Cap Growth Fund | N/A | 25,189 | N/A | N/A |
VP – Partners Small Cap Value Fund | N/A | 19,407 | 119,219 | N/A |
VP – Select Large Cap Equity Fund | N/A | 7 | N/A | N/A |
VP – Select Large Cap Value Fund | N/A | 71,889 | 66,843 | N/A |
VP – Select Mid Cap Value Fund | N/A | 76,700 | 84,425 | N/A |
VP – Select Small Cap Value Fund | N/A | 65,759 | 68,065 | N/A |
VP – Seligman Global Technology Fund | N/A | 114,926 | N/A | N/A |
VP – T. Rowe Price Large Cap Value Fund | N/A | 59,626 | N/A | N/A |
VP – TCW Core Plus Bond Fund | N/A | 24,290 | N/A | N/A |
VP – U.S. Government Mortgage Fund | N/A | 60,770 | 122,615 | N/A |
VP – Victory Sycamore Established Value Fund | N/A | 119,213 | 77,540 | N/A |
VP – Wells Fargo Short Duration Government Fund | N/A | 70,586 | N/A | N/A |
VP – Westfield Mid Cap Growth Fund | N/A | 56,838 | N/A | N/A |
Statement of Additional Information – May 1, 2020 | 141 |
Amounts Reimbursed | |||
2019 | 2018 | 2017 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $45,084 | $0 | $0 |
VP – American Century Diversified Bond Fund | 0 | 0 | 0 |
VP – Balanced Fund | 299,030 | 348,036 | 285,453 |
VP – BlackRock Global Inflation-Protected Securities Fund | 113,940 | 104,233 | 117,830 |
VP – CenterSquare Real Estate Fund | 0 | 0 | 0 |
VP – Commodity Strategy Fund | 0 | 0 | 0 |
VP – Conservative Portfolio | 0 | 30,349 | 0 |
VP – Core Equity Fund | 95,774 | 89,679 | 104,879 |
VP – Disciplined Core Fund | 0 | 0 | 0 |
VP – Dividend Opportunity Fund | 248,805 | 95,533 | 0 |
VP – Emerging Markets Bond Fund | 0 | 0 | 0 |
Statement of Additional Information – May 1, 2020 | 142 |
Amounts Reimbursed | |||
2019 | 2018 | 2017 | |
VP – Emerging Markets Fund | $231,499 | $14,894 | $93,744 |
VP – Global Strategic Income Fund | 321,838 | 268,853 | 259,620 |
VP – Government Money Market Fund | 422,904 | 527,207 | 156,567 |
VP – High Yield Bond Fund | 289,812 | 104,632 | 4,486 |
VP – Income Opportunities Fund | 208,907 | 49,400 | 0 |
VP – Intermediate Bond Fund | 0 | 0 | 0 |
VP – Large Cap Growth Fund | 0 | 0 | 138,527 |
VP – Large Cap Index Fund | 0 | 0 | 0 |
VP – Limited Duration Credit Fund | 46,807 | 0 | 0 |
VP – Loomis Sayles Growth Fund | 0 | 0 | 0 |
VP – Los Angeles Capital Large Cap Growth Fund | 0 | 0 | 0 |
VP – MFS Value Fund | 0 | 0 | 0 |
VP – Mid Cap Growth Fund | 771,597 | 730,049 | 764,057 |
VP – Moderate Portfolio | 0 | 0 | 0 |
VP – Moderately Aggressive Portfolio | 0 | 0 | 0 |
VP – Moderately Conservative Portfolio | 249,739 | 92,397 | 0 |
VP – Morgan Stanley Advantage Fund | 0 | 0 | 0 |
VP – MV Moderate Growth Fund | 0 | 0 | 0 |
VP – Overseas Core Fund | 0 | 0 | 102,181 |
VP – Partners Core Bond Fund | 0 | 0 | 0 |
VP – Partners Core Equity Fund | 238,968 | 193,950 | 15,574 |
VP – Partners International Core Equity Fund | 0 | 0 | 0 |
VP – Partners International Growth Fund | 117,879 | 0 | 0 |
VP – Partners International Value Fund | 0 | 0 | 0 |
VP – Partners Small Cap Growth Fund | 63,773 | 58,245 | 0 |
VP – Partners Small Cap Value Fund | 36,475 | 20,827 | 0 |
VP – Select Large Cap Equity Fund | 608,660 | 404,618(a) | N/A |
VP – Select Large Cap Value Fund | 13,093 | 0 | 101,722 |
VP – Select Mid Cap Value Fund | 177,558 | 110,229 | 128,245 |
VP – Select Small Cap Value Fund | 144,870 | 156,773 | 156,295 |
VP – Seligman Global Technology Fund | 182,453 | 50,702 | 103,560 |
VP – T. Rowe Price Large Cap Value Fund | 0 | 0 | 0 |
VP – TCW Core Plus Bond Fund | 0 | 0 | 0 |
VP – U.S. Government Mortgage Fund | 0 | 0 | 0 |
VP – Victory Sycamore Established Value Fund | 0 | 0 | 112 |
VP – Wells Fargo Short Duration Government Fund | 0 | 0 | 0 |
VP – Westfield Mid Cap Growth Fund | 0 | 18,547 | 0 |
(a) | For the period from January 4, 2018 (commencement of operations) to December 31, 2018. |
Statement of Additional Information – May 1, 2020 | 143 |
Statement of Additional Information – May 1, 2020 | 144 |
Statement of Additional Information – May 1, 2020 | 145 |
Statement of Additional Information – May 1, 2020 | 146 |
Statement of Additional Information – May 1, 2020 | 147 |
Statement of Additional Information – May 1, 2020 | 148 |
Statement of Additional Information – May 1, 2020 | 149 |
Name, address, year of birth |
Position held with Subsidiary
and length of service |
Principal occupation during past five years |
Jonathan C. Cleasby
225 Franklin Street Boston, MA 02110 Born 1977 |
Director since
March 2020 |
Vice President, Ameriprise Financial, Inc.
since March 2020 |
Christopher O. Petersen
5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1970 |
Director since
January 2015 |
See Fund Governance – Fund Officers. |
Subsidiary |
Assets
(millions) |
Annual rate at
each asset level(a) |
CVPCSF Offshore Fund, Ltd.
(Subsidiary of VP – Commodity Strategy Fund) |
$0 - $500 | 0.630% |
>$500 - $1,000 | 0.580% | |
>$1,000 - $3,000 | 0.550% | |
>$3,000 - $6,000 | 0.520% | |
>$6,000 - $12,000 | 0.500% | |
>$12,000 | 0.490% |
(a) | When calculating asset levels for purposes of determining fee rate breakpoints, asset levels are based on aggregate net assets of the Fund and the Parent Fund. When calculating the fee payable under this agreement, the annual rates are based on a percentage of the average daily net assets of the Fund. |
Statement of Additional Information – May 1, 2020 | 150 |
Statement of Additional Information – May 1, 2020 | 151 |
Name, Address,
Year of Birth |
Position Held
with the Trust and Length of Service |
Principal Occupation(s)
During the Past Five Years and Other Relevant Professional Experience |
Number of
Funds in the Columbia Funds Complex Overseen |
Other Directorships Held by Trustee During the Past Five Years |
Committee
Assignments |
George S. Batejan
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1953 |
Trustee since 1/17 | Executive Vice President, Global Head of Technology and Operations, Janus Capital Group, Inc., 2010-2016 | 117 | Former Chairman of the Board, NICSA (National Investment Company Services Association) (Executive Committee, Nominating Committee and Governance Committee), 2014-2016; former Director, Intech Investment Management, 2011-2016; former Board Member, Metro Denver Chamber of Commerce, 2015-2016; former Advisory Board Member, University of Colorado Business School, 2015-2018 | Compliance, Contracts, Executive, Investment Review |
Kathleen Blatz
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee since 1/06 for RiverSource Funds and since 6/11 for Nations Funds | Attorney, specializing in arbitration and mediation; Chief Justice, Minnesota Supreme Court, 1998-2006; Associate Justice, Minnesota Supreme Court, 1996-1998; Fourth Judicial District Court Judge, Hennepin County, 1994-1996; Attorney in private practice and public service, 1984-1993; State Representative, Minnesota House of Representatives, 1979-1993, which included service on the Tax and Financial Institutions and Insurance Committees; Member and Interim Chair, Minnesota Sports Facilities Authority, January -July 2017; Interim President and Chief Executive Officer, Blue Cross and Blue Shield of Minnesota (health care insurance), February-July 2018 | 117 | Trustee, BlueCross BlueShield of Minnesota since 2009 (Chair of the Business Development Committee 2014-2017; Chair of the Governance Committee since 2017); Chair of the Robina Foundation since August 2013; former Member and Chair of the Board, Minnesota Sports Facilities Authority, January 2017-July 2017 | Board Governance, Compliance, Contracts, Executive, Investment Review |
Statement of Additional Information – May 1, 2020 | 152 |
Name, Address,
Year of Birth |
Position Held
with the Trust and Length of Service |
Principal Occupation(s)
During the Past Five Years and Other Relevant Professional Experience |
Number of
Funds in the Columbia Funds Complex Overseen |
Other Directorships Held by Trustee During the Past Five Years |
Committee
Assignments |
Pamela G. Carlton
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee since 7/07 for RiverSource Funds and since 6/11 for Nations Funds | President, Springboard- Partners in Cross Cultural Leadership (consulting company) since 2003; Managing Director of US Equity Research, JP Morgan Chase, 1999-2003; Director of US Equity Research, Chase Asset Management, 1996- 1999; Co-Director Latin America Research, 1993-1996, COO Global Research, 1992-1996, Co-Director of US Research, 1991-1992, Investment Banker, Morgan Stanley, 1982-1991 | 117 | Trustee, New York Presbyterian Hospital Board (Executive Committee and Chair of Human Resources Committee) since 1996; Director, DR Bank (Audit Committee) since 2017; Director, Evercore Inc. (Audit Committee, Nominating and Governance Committee) since 2019 | Audit, Board Governance, Contracts, Executive, Investment Review |
Patricia M. Flynn
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1950 |
Trustee since 11/04 for RiverSource Funds and since 6/11 for Nations Funds | Trustee Professor of Economics and Management, Bentley University since 1976 (also teaches and conducts research on corporate governance); Dean, McCallum Graduate School of Business, Bentley University, 1992-2002 | 117 | Trustee, MA Taxpayers Foundation since 1997; Board of Governors, Innovation Institute, MA Technology Collaborative since 2010; Board of Directors, The MA Business Roundtable 2003-2019 | Audit, Board Governance, Contracts, Executive, Investment Review |
Brian J. Gallagher
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee since 12/17 | Retired; Partner with Deloitte & Touche LLP and its predecessors, 1977-2016 | 117 | Trustee, Catholic Schools Foundation since 2004 | Audit, Contracts, Executive, Investment Review |
Catherine James Paglia
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1952 |
Chair of the Board since 1/20; Trustee since 11/04 for RiverSource Funds and since 6/11 for Nations Funds | Director, Enterprise Asset Management, Inc. (private real estate and asset management company) since September 1998; Managing Director and Partner, Interlaken Capital, Inc., 1989-1997; Managing Director, Morgan Stanley, 1982-1989; Vice President, Investment Banking, 1980-1982, Associate, Investment Banking, 1976-1980, Dean Witter Reynolds, Inc. | 117 | Director, Valmont Industries, Inc. (irrigation systems manufacturer) since 2012; Trustee, Carleton College (on the Investment Committee); Trustee, Carnegie Endowment for International Peace (on the Investment Committee) | Board Governance, Compliance, Contracts, Executive, Investment Review |
Statement of Additional Information – May 1, 2020 | 153 |
Name, Address,
Year of Birth |
Position Held
with the Trust and Length of Service |
Principal Occupation(s)
During the Past Five Years and Other Relevant Professional Experience |
Number of
Funds in the Columbia Funds Complex Overseen |
Other Directorships Held by Trustee During the Past Five Years |
Committee
Assignments |
Anthony M. Santomero
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1946 |
Trustee since 6/11 for RiverSource Funds and since 1/08 for Nations Funds | Richard K. Mellon Professor Emeritus of Finance, The Wharton School, University of Pennsylvania, since 2002; Senior Advisor, McKinsey & Company (consulting), 2006-2008; President, Federal Reserve Bank of Philadelphia, 2000-2006; Professor of Finance, The Wharton School, University of Pennsylvania, 1972-2002 | 117 | Trustee, Penn Mutual Life Insurance Company since March 2008; Director, Renaissance Reinsurance Ltd. since May 2008; former Director, Citigroup Inc. and Citibank, N.A., 2009-2019; former Trustee, BofA Funds Series Trust (11 funds), 2008-2011 | Audit, Board Governance, Contracts, Investment Review |
Minor M. Shaw
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1947 |
Trustee since 6/11 for RiverSource Funds and since 2003 for Nations Funds | President, Micco LLC (private investments) since 2011; President, Micco Corp. (family investment business), 1998-2011 | 117 | Director, BlueCross BlueShield of South Carolina since April 2008; Trustee, Hollingsworth Funds since 2016 (previously Board Chair from 2016-2019); Advisory Board member, Duke Energy Corp. since October 2016; Chair of the Duke Endowment; Chair of Greenville – Spartanburg Airport Commission; former Trustee, BofA Funds Series Trust (11 funds), 2003-2011; former Director, Piedmont Natural Gas, 2004-2016; former Director, National Association of Corporate Directors, Carolinas Chapter, 2013-2018 | Board Governance, Compliance, Contracts, Investment Review |
Sandra Yeager
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1964 |
Trustee since 12/17 | Retired; President and founder, Hanoverian Capital, LLC (SEC registered investment advisor firm), 2008-2016; Managing Director, DuPont Capital, 2006-2008; Managing Director, Morgan Stanley Investment Management, 2004-2006; Senior Vice President, Alliance Bernstein, 1990-2004 | 115 | Director, NAPE Education Foundation since October 2016 | Audit, Contracts, Investment Review |
Statement of Additional Information – May 1, 2020 | 154 |
* | Interested person (as defined under the 1940 Act) by reason of being an officer, director, security holder and/or employee of the Investment Manager or Ameriprise Financial. |
Statement of Additional Information – May 1, 2020 | 155 |
Name, Address
and Year of Birth |
Position and Year
First Appointed to Position for any Fund in the Columbia Funds Complex or a Predecessor Thereof |
Principal Occupation(s) During Past Five Years |
Joseph Beranek
5890 Ameriprise Financial Center Minneapolis, MN 55474 Born 1965 |
Treasurer, Chief Accounting Officer (Principal Accounting Officer) (2019) and Principal Financial Officer (2020) | Vice President - Mutual Fund Accounting and Financial Reporting, Columbia Management Investment Advisers, LLC, since December 2018 and March 2017, respectively (previously Vice President – Pricing and Corporate Actions, May 2010 - March 2017). |
Paul B. Goucher
485 Lexington Avenue New York, NY 10017 Born 1968 |
Senior Vice President (2011) and Assistant Secretary (2008) | Senior Vice President and Assistant General Counsel, Ameriprise Financial, Inc. since January 2017 (previously Vice President and Lead Chief Counsel, November 2008 – January 2017 and January 2013 – January 2017, respectively); Vice President, Chief Legal Officer and Assistant Secretary, Columbia Management Investment Advisers, LLC since March 2015 (previously Vice President and Assistant Secretary, May 2010 – March 2015). |
Thomas P. McGuire
225 Franklin Street Boston, MA 02110 Born 1972 |
Senior Vice President and Chief Compliance Officer (2012) | Vice President – Asset Management Compliance, Ameriprise Financial, Inc., since May 2010; Chief Compliance Officer, Ameriprise Certificate Company since September 2010; Chief Compliance Officer, Columbia Acorn/Wanger Funds since December 2015. |
Colin Moore
225 Franklin Street Boston, MA 02110 Born 1958 |
Senior Vice President (2010) | Executive Vice President and Global Chief Investment Officer, Ameriprise Financial, Inc., since July 2013; Executive Vice President and Global Chief Investment Officer, Columbia Management Investment Advisers, LLC since July 2013. |
Ryan C. Larrenaga
225 Franklin Street Boston, MA 02110 Born 1970 |
Senior Vice President (2017), Chief Legal Officer (2017) and Secretary (2015) | Vice President and Chief Counsel, Ameriprise Financial, Inc. since August 2018 (previously Vice President and Group Counsel, August 2011 – August 2018); officer of Columbia Funds and affiliated funds since 2005. |
Daniel J. Beckman
225 Franklin Street Boston, MA 02110 Born 1962 |
Senior Vice President (2020) | Vice President – Head of North America Product, Columbia Management Investment Advisers, LLC (since April 2015); previously, Senior Vice President of Investment Product Management, Fidelity Financial Advisor Solutions, a division of Fidelity Investments (January 2012 – March 2015). |
Michael E. DeFao
225 Franklin Street Boston, MA 02110 Born 1968 |
Vice President (2011) and Assistant Secretary (2010) | Vice President and Chief Counsel, Ameriprise Financial, Inc. since May 2010. |
Lyn Kephart-Strong
5228 Ameriprise Financial Center Minneapolis, MN 55474 Born 1960 |
Vice President (2015) | President, Columbia Management Investment Services Corp. since October 2014; Vice President & Resolution Officer, Ameriprise Trust Company since August 2009. |
Statement of Additional Information – May 1, 2020 | 156 |
Statement of Additional Information – May 1, 2020 | 157 |
Statement of Additional Information – May 1, 2020 | 158 |
Statement of Additional Information – May 1, 2020 | 159 |
Board Member |
Aggregate
Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
George S. Batejan | Over $100,000 |
Kathleen Blatz | Over $100,000 |
Pamela G. Carlton | Over $100,000(a) |
Patricia M. Flynn | Over $100,000(a) |
Brian J. Gallagher | Over $100,000(a) |
Catherine James Paglia | Over $100,000(a) |
Anthony Santomero | Over $100,000(a) |
Minor M. Shaw | Over $100,000(a)(b) |
Sandra L. Yeager | Over $100,000(a) |
(a) | Includes the value of compensation payable under a Deferred Compensation Plan that is determined as if the amounts deferred had been invested, as of the date of deferral, in shares of one or more funds in the Columbia Funds Complex overseen by the Trustee as specified by the Trustee. |
(b) | Ms. Shaw invests in a Section 529 Plan managed by the Investment Manager that allocates assets to various open-end funds, including Columbia Funds. The amount shown in the table includes the value of her interest in this plan determined as if her investment in the plan were invested directly in the Columbia Fund pursuant to the plan’s target allocations. |
Statement of Additional Information – May 1, 2020 | 160 |
Board Member |
Aggregate
Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
William F. Truscott | Over $100,000 |
Trustees(a) |
Total Cash Compensation
from Fund Complex Paid to Trustee(b) |
Amount Deferred
from Total Compensation(c) |
George Batejan | $365,000 | $0 |
Kathleen Blatz | $362,500 | $0 |
Edward Boudreau(d) | $445,000 | $275,900 |
Pamela Carlton | $362,500 | $108,750 |
Patricia Flynn | $362,500 | $362,500 |
Brian Gallagher | $325,000 | $162,500 |
Catherine Paglia | $362,500 | $362,500 |
Anthony Santomero | $330,000 | $0 |
Minor Shaw | $332,500 | $166,250 |
Sandra Yeager | $325,000 | $162,500 |
(a) | Trustee compensation is paid by the Funds and is comprised of a combination of a base fee and meeting fees, with the exception of the Chair of the Board, who receives a base annual compensation. |
(b) | Includes any portion of cash compensation Trustees elected to defer during the fiscal period. |
(c) | The Trustees may elect to defer a portion of the total cash compensation payable. Additional information regarding the Deferred Compensation Plan is described below. |
(d) | Mr. Boudreau served as Trustee until December 31, 2019, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
Statement of Additional Information – May 1, 2020 | 161 |
Fund |
Aggregate Compensation from Fund
Independent Trustees |
||||
Batejan | Blatz | Boudreau(a) | Carlton | Flynn | |
For Funds with fiscal period ending December 31 | |||||
VP - Aggressive Portfolio | $4,237 | $4,207 | $5,191 | $4,207 | $4,207 |
Amount Deferred | $0 | $0 | $3,218 | $1,262 | $4,207 |
VP - American Century Diversified Bond Fund | $3,739 | $3,714 | $4,583 | $3,714 | $3,714 |
Amount Deferred | $0 | $0 | $2,841 | $1,114 | $3,714 |
VP - Balanced Fund | $2,387 | $2,369 | $2,922 | $2,370 | $2,370 |
Amount Deferred | $0 | $0 | $1,812 | $711 | $2,370 |
VP - BlackRock Global Inflation-Protected Securities Fund | $1,142 | $1,134 | $1,398 | $1,134 | $1,134 |
Amount Deferred | $0 | $0 | $866 | $340 | $1,134 |
VP - CenterSquare Real Estate Fund | $1,644 | $1,631 | $2,010 | $1,632 | $1,632 |
Amount Deferred | $0 | $0 | $1,246 | $490 | $1,632 |
VP - Commodity Strategy Fund | $1,496 | $1,485 | $1,831 | $1,485 | $1,485 |
Amount Deferred | $0 | $0 | $1,135 | $446 | $1,485 |
VP - Conservative Portfolio | $2,345 | $2,328 | $2,871 | $2,329 | $2,329 |
Amount Deferred | $0 | $0 | $1,780 | $699 | $2,329 |
VP - Core Equity Fund | $1,242 | $1,233 | $1,520 | $1,233 | $1,233 |
Amount Deferred | $0 | $0 | $942 | $370 | $1,233 |
VP - Disciplined Core Fund | $7,774 | $7,720 | $9,529 | $7,719 | $7,719 |
Amount Deferred | $0 | $0 | $5,908 | $2,316 | $7,719 |
VP - Dividend Opportunity Fund | $2,881 | $2,860 | $3,528 | $2,861 | $2,861 |
Amount Deferred | $0 | $0 | $2,187 | $858 | $2,861 |
VP - Emerging Markets Bond Fund | $1,341 | $1,331 | $1,640 | $1,331 | $1,331 |
Amount Deferred | $0 | $0 | $1,017 | $399 | $1,331 |
VP - Emerging Markets Fund | $1,571 | $1,559 | $1,924 | $1,560 | $1,560 |
Amount Deferred | $0 | $0 | $1,193 | $468 | $1,560 |
VP - Global Strategic Income Fund | $1,143 | $1,134 | $1,398 | $1,135 | $1,135 |
Amount Deferred | $0 | $0 | $867 | $340 | $1,135 |
VP - Government Money Market Fund | $1,533 | $1,522 | $1,879 | $1,522 | $1,522 |
Amount Deferred | $0 | $0 | $1,165 | $457 | $1,522 |
VP - High Yield Bond Fund | $1,445 | $1,434 | $1,768 | $1,435 | $1,435 |
Amount Deferred | $0 | $0 | $1,096 | $430 | $1,435 |
VP - Income Opportunities Fund | $1,437 | $1,426 | $1,758 | $1,427 | $1,427 |
Amount Deferred | $0 | $0 | $1,090 | $428 | $1,427 |
VP - Intermediate Bond Fund | $6,924 | $6,875 | $8,477 | $6,877 | $6,877 |
Amount Deferred | $0 | $0 | $5,256 | $2,063 | $6,877 |
VP - Large Cap Growth Fund | $3,392 | $3,367 | $4,153 | $3,368 | $3,368 |
Amount Deferred | $0 | $0 | $2,575 | $1,010 | $3,368 |
VP - Large Cap Index Fund | $2,259 | $2,242 | $2,765 | $2,244 | $2,244 |
Amount Deferred | $0 | $0 | $1,714 | $673 | $2,244 |
VP - Limited Duration Credit Fund | $1,986 | $1,972 | $2,431 | $1,972 | $1,972 |
Amount Deferred | $0 | $0 | $1,507 | $592 | $1,972 |
VP - Loomis Sayles Growth Fund | $3,945 | $3,915 | $4,830 | $3,917 | $3,917 |
Amount Deferred | $0 | $0 | $2,994 | $1,175 | $3,917 |
VP - Los Angeles Capital Large Cap Growth Fund | $3,334 | $3,310 | $4,083 | $3,311 | $3,311 |
Amount Deferred | $0 | $0 | $2,531 | $993 | $3,311 |
VP - MFS Value Fund | $3,094 | $3,074 | $3,793 | $3,072 | $3,072 |
Amount Deferred | $0 | $0 | $2,351 | $922 | $3,072 |
VP - Mid Cap Growth Fund | $1,636 | $1,623 | $2,001 | $1,624 | $1,624 |
Amount Deferred | $0 | $0 | $1,240 | $487 | $1,624 |
Statement of Additional Information – May 1, 2020 | 162 |
Fund |
Aggregate Compensation from Fund
Independent Trustees |
||||
Batejan | Blatz | Boudreau(a) | Carlton | Flynn | |
VP - Moderate Portfolio | $22,993 | $22,831 | $28,167 | $22,832 | $22,832 |
Amount Deferred | $0 | $0 | $17,464 | $6,849 | $22,832 |
VP - Moderately Aggressive Portfolio | $11,169 | $11,092 | $13,687 | $11,089 | $11,089 |
Amount Deferred | $0 | $0 | $8,486 | $3,327 | $11,089 |
VP - Moderately Conservative Portfolio | $4,844 | $4,810 | $5,933 | $4,810 | $4,810 |
Amount Deferred | $0 | $0 | $3,678 | $1,443 | $4,810 |
VP - Morgan Stanley Advantage Fund | $3,917 | $3,886 | $4,789 | $3,889 | $3,889 |
Amount Deferred | $0 | $0 | $2,969 | $1,167 | $3,889 |
VP - MV Moderate Growth Fund | $19,869 | $19,726 | $24,336 | $19,730 | $19,730 |
Amount Deferred | $0 | $0 | $15,088 | $5,919 | $19,730 |
VP - Overseas Core Fund | $2,413 | $2,395 | $2,955 | $2,396 | $2,396 |
Amount Deferred | $0 | $0 | $1,832 | $719 | $2,396 |
VP - Partners Core Bond Fund | $5,656 | $5,615 | $6,924 | $5,616 | $5,616 |
Amount Deferred | $0 | $0 | $4,293 | $1,685 | $5,616 |
VP - Partners Core Equity Fund | $3,656 | $3,629 | $4,478 | $3,631 | $3,631 |
Amount Deferred | $0 | $0 | $2,776 | $1,089 | $3,631 |
VP - Partners International Core Equity Fund | $4,813 | $4,778 | $5,903 | $4,779 | $4,779 |
Amount Deferred | $0 | $0 | $3,660 | $1,434 | $4,779 |
VP - Partners International Growth Fund | $2,127 | $2,112 | $2,601 | $2,112 | $2,112 |
Amount Deferred | $0 | $0 | $1,612 | $634 | $2,112 |
VP - Partners International Value Fund | $2,120 | $2,106 | $2,593 | $2,106 | $2,106 |
Amount Deferred | $0 | $0 | $1,608 | $632 | $2,106 |
VP - Partners Small Cap Growth Fund | $1,811 | $1,798 | $2,217 | $1,798 | $1,798 |
Amount Deferred | $0 | $0 | $1,375 | $539 | $1,798 |
VP - Partners Small Cap Value Fund | $1,925 | $1,911 | $2,357 | $1,912 | $1,912 |
Amount Deferred | $0 | $0 | $1,461 | $573 | $1,912 |
VP - Select Large Cap Equity Fund | $2,564 | $2,545 | $3,140 | $2,546 | $2,546 |
Amount Deferred | $0 | $0 | $1,947 | $764 | $2,546 |
VP - Select Large Cap Value Fund | $2,636 | $2,617 | $3,231 | $2,617 | $2,617 |
Amount Deferred | $0 | $0 | $2,003 | $785 | $2,617 |
VP - Select Mid Cap Value Fund | $1,377 | $1,367 | $1,686 | $1,368 | $1,368 |
Amount Deferred | $0 | $0 | $1,045 | $410 | $1,368 |
VP - Select Small Cap Value Fund | $1,104 | $1,096 | $1,351 | $1,097 | $1,097 |
Amount Deferred | $0 | $0 | $838 | $329 | $1,097 |
VP - Seligman Global Technology Fund | $1,101 | $1,093 | $1,347 | $1,093 | $1,093 |
Amount Deferred | $0 | $0 | $835 | $328 | $1,093 |
VP - T. Rowe Price Large Cap Value Fund | $3,580 | $3,556 | $4,389 | $3,555 | $3,555 |
Amount Deferred | $0 | $0 | $2,721 | $1,066 | $3,555 |
VP - TCW Core Plus Bond Fund | $4,566 | $4,533 | $5,590 | $4,535 | $4,535 |
Amount Deferred | $0 | $0 | $3,466 | $1,360 | $4,535 |
VP - U.S. Government Mortgage Fund | $2,270 | $2,253 | $2,778 | $2,254 | $2,254 |
Amount Deferred | $0 | $0 | $1,722 | $676 | $2,254 |
VP - Victory Sycamore Established Value Fund | $1,784 | $1,771 | $2,184 | $1,772 | $1,772 |
Amount Deferred | $0 | $0 | $1,354 | $532 | $1,772 |
VP - Wells Fargo Short Duration Government Fund | $3,552 | $3,527 | $4,350 | $3,528 | $3,528 |
Amount Deferred | $0 | $0 | $2,697 | $1,058 | $3,528 |
VP - Westfield Mid Cap Growth Fund | $1,755 | $1,742 | $2,147 | $1,743 | $1,743 |
Amount Deferred | $0 | $0 | $1,331 | $523 | $1,743 |
(a) | Mr. Boudreau served as Trustee until December 31, 2019, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
Statement of Additional Information – May 1, 2020 | 163 |
Fund |
Aggregate Compensation from Fund
Independent Trustees |
||||
Gallagher | Paglia | Santomero | Shaw | Yeager | |
For Funds with fiscal period ending December 31 | |||||
VP - Aggressive Portfolio | $3,876 | $4,207 | $3,816 | $3,847 | $3,877 |
Amount Deferred | $1,938 | $4,207 | $0 | $1,923 | $1,938 |
VP - American Century Diversified Bond Fund | $3,436 | $3,714 | $3,385 | $3,411 | $3,436 |
Amount Deferred | $1,718 | $3,714 | $0 | $1,705 | $1,718 |
VP - Balanced Fund | $2,184 | $2,369 | $2,150 | $2,167 | $2,183 |
Amount Deferred | $1,092 | $2,369 | $0 | $1,083 | $1,092 |
VP - BlackRock Global Inflation-Protected Securities Fund | $1,045 | $1,134 | $1,029 | $1,036 | $1,044 |
Amount Deferred | $522 | $1,134 | $0 | $518 | $522 |
VP - CenterSquare Real Estate Fund | $1,504 | $1,631 | $1,480 | $1,492 | $1,503 |
Amount Deferred | $752 | $1,631 | $0 | $746 | $751 |
VP - Commodity Strategy Fund | $1,367 | $1,485 | $1,346 | $1,356 | $1,367 |
Amount Deferred | $684 | $1,485 | $0 | $678 | $683 |
VP - Conservative Portfolio | $2,147 | $2,328 | $2,114 | $2,130 | $2,146 |
Amount Deferred | $1,073 | $2,328 | $0 | $1,065 | $1,073 |
VP - Core Equity Fund | $1,136 | $1,233 | $1,118 | $1,127 | $1,136 |
Amount Deferred | $568 | $1,233 | $0 | $564 | $568 |
VP - Disciplined Core Fund | $7,117 | $7,720 | $7,007 | $7,062 | $7,117 |
Amount Deferred | $3,558 | $7,720 | $0 | $3,531 | $3,559 |
VP - Dividend Opportunity Fund | $2,636 | $2,860 | $2,595 | $2,615 | $2,636 |
Amount Deferred | $1,318 | $2,860 | $0 | $1,308 | $1,318 |
VP - Emerging Markets Bond Fund | $1,226 | $1,331 | $1,207 | $1,216 | $1,225 |
Amount Deferred | $613 | $1,331 | $0 | $608 | $613 |
VP - Emerging Markets Fund | $1,437 | $1,559 | $1,415 | $1,426 | $1,437 |
Amount Deferred | $719 | $1,559 | $0 | $713 | $718 |
VP - Global Strategic Income Fund | $1,045 | $1,134 | $1,029 | $1,037 | $1,045 |
Amount Deferred | $523 | $1,134 | $0 | $518 | $522 |
VP - Government Money Market Fund | $1,405 | $1,522 | $1,384 | $1,395 | $1,405 |
Amount Deferred | $703 | $1,522 | $0 | $697 | $703 |
VP - High Yield Bond Fund | $1,322 | $1,434 | $1,301 | $1,311 | $1,321 |
Amount Deferred | $661 | $1,434 | $0 | $656 | $661 |
VP - Income Opportunities Fund | $1,314 | $1,426 | $1,294 | $1,304 | $1,314 |
Amount Deferred | $657 | $1,426 | $0 | $652 | $657 |
VP - Intermediate Bond Fund | $6,340 | $6,875 | $6,242 | $6,290 | $6,338 |
Amount Deferred | $3,170 | $6,875 | $0 | $3,145 | $3,169 |
VP - Large Cap Growth Fund | $3,103 | $3,367 | $3,055 | $3,078 | $3,102 |
Amount Deferred | $1,552 | $3,367 | $0 | $1,539 | $1,551 |
VP - Large Cap Index Fund | $2,067 | $2,242 | $2,035 | $2,050 | $2,066 |
Amount Deferred | $1,034 | $2,242 | $0 | $1,025 | $1,033 |
VP - Limited Duration Credit Fund | $1,817 | $1,972 | $1,789 | $1,803 | $1,817 |
Amount Deferred | $909 | $1,972 | $0 | $902 | $908 |
VP - Loomis Sayles Growth Fund | $3,608 | $3,915 | $3,552 | $3,579 | $3,607 |
Amount Deferred | $1,804 | $3,915 | $0 | $1,789 | $1,803 |
VP - Los Angeles Capital Large Cap Growth Fund | $3,051 | $3,310 | $3,003 | $3,026 | $3,049 |
Amount Deferred | $1,525 | $3,310 | $0 | $1,513 | $1,525 |
VP - MFS Value Fund | $2,833 | $3,074 | $2,790 | $2,813 | $2,835 |
Amount Deferred | $1,416 | $3,074 | $0 | $1,406 | $1,417 |
VP - Mid Cap Growth Fund | $1,495 | $1,623 | $1,472 | $1,483 | $1,494 |
Amount Deferred | $748 | $1,623 | $0 | $741 | $747 |
VP - Moderate Portfolio | $21,044 | $22,831 | $20,719 | $20,882 | $21,044 |
Amount Deferred | $10,522 | $22,831 | $0 | $10,441 | $10,522 |
Statement of Additional Information – May 1, 2020 | 164 |
Fund |
Aggregate Compensation from Fund
Independent Trustees |
||||
Gallagher | Paglia | Santomero | Shaw | Yeager | |
VP - Moderately Aggressive Portfolio | $10,221 | $11,092 | $10,064 | $10,144 | $10,223 |
Amount Deferred | $5,111 | $11,092 | $0 | $5,072 | $5,112 |
VP - Moderately Conservative Portfolio | $4,434 | $4,810 | $4,366 | $4,400 | $4,434 |
Amount Deferred | $2,217 | $4,810 | $0 | $2,200 | $2,217 |
VP - Morgan Stanley Advantage Fund | $3,577 | $3,886 | $3,520 | $3,547 | $3,574 |
Amount Deferred | $1,789 | $3,886 | $0 | $1,773 | $1,787 |
VP - MV Moderate Growth Fund | $18,184 | $19,726 | $17,902 | $18,041 | $18,180 |
Amount Deferred | $9,092 | $19,726 | $0 | $9,020 | $9,090 |
VP - Overseas Core Fund | $2,208 | $2,395 | $2,174 | $2,191 | $2,207 |
Amount Deferred | $1,104 | $2,395 | $0 | $1,095 | $1,104 |
VP - Partners Core Bond Fund | $5,177 | $5,615 | $5,097 | $5,136 | $5,175 |
Amount Deferred | $2,588 | $5,615 | $0 | $2,568 | $2,588 |
VP - Partners Core Equity Fund | $3,346 | $3,629 | $3,294 | $3,319 | $3,345 |
Amount Deferred | $1,673 | $3,629 | $0 | $1,660 | $1,672 |
VP - Partners International Core Equity Fund | $4,398 | $4,778 | $4,328 | $4,363 | $4,397 |
Amount Deferred | $2,199 | $4,778 | $0 | $2,181 | $2,199 |
VP - Partners International Growth Fund | $1,949 | $2,112 | $1,919 | $1,934 | $1,949 |
Amount Deferred | $974 | $2,112 | $0 | $967 | $975 |
VP - Partners International Value Fund | $1,944 | $2,106 | $1,915 | $1,930 | $1,945 |
Amount Deferred | $972 | $2,106 | $0 | $965 | $972 |
VP - Partners Small Cap Growth Fund | $1,655 | $1,798 | $1,628 | $1,641 | $1,654 |
Amount Deferred | $827 | $1,798 | $0 | $821 | $827 |
VP - Partners Small Cap Value Fund | $1,759 | $1,911 | $1,732 | $1,745 | $1,759 |
Amount Deferred | $880 | $1,911 | $0 | $873 | $880 |
VP - Select Large Cap Equity Fund | $2,346 | $2,545 | $2,310 | $2,327 | $2,345 |
Amount Deferred | $1,173 | $2,545 | $0 | $1,164 | $1,173 |
VP - Select Large Cap Value Fund | $2,412 | $2,617 | $2,375 | $2,394 | $2,412 |
Amount Deferred | $1,206 | $2,617 | $0 | $1,197 | $1,206 |
VP - Select Mid Cap Value Fund | $1,260 | $1,367 | $1,240 | $1,250 | $1,259 |
Amount Deferred | $630 | $1,367 | $0 | $625 | $630 |
VP - Select Small Cap Value Fund | $1,010 | $1,096 | $994 | $1,002 | $1,010 |
Amount Deferred | $505 | $1,096 | $0 | $501 | $505 |
VP - Seligman Global Technology Fund | $1,007 | $1,093 | $992 | $999 | $1,007 |
Amount Deferred | $504 | $1,093 | $0 | $500 | $503 |
VP - T. Rowe Price Large Cap Value Fund | $3,279 | $3,556 | $3,229 | $3,255 | $3,280 |
Amount Deferred | $1,639 | $3,556 | $0 | $1,627 | $1,640 |
VP - TCW Core Plus Bond Fund | $4,180 | $4,533 | $4,116 | $4,148 | $4,179 |
Amount Deferred | $2,090 | $4,533 | $0 | $2,074 | $2,090 |
VP - U.S. Government Mortgage Fund | $2,077 | $2,253 | $2,045 | $2,061 | $2,077 |
Amount Deferred | $1,039 | $2,253 | $0 | $1,031 | $1,038 |
VP - Victory Sycamore Established Value Fund | $1,632 | $1,771 | $1,606 | $1,618 | $1,631 |
Amount Deferred | $816 | $1,771 | $0 | $809 | $815 |
VP - Wells Fargo Short Duration Government Fund | $3,251 | $3,527 | $3,200 | $3,225 | $3,250 |
Amount Deferred | $1,625 | $3,527 | $0 | $1,613 | $1,625 |
VP - Westfield Mid Cap Growth Fund | $1,603 | $1,742 | $1,578 | $1,590 | $1,602 |
Amount Deferred | $802 | $1,742 | $0 | $795 | $801 |
Statement of Additional Information – May 1, 2020 | 165 |
Statement of Additional Information – May 1, 2020 | 166 |
Statement of Additional Information – May 1, 2020 | 167 |
Statement of Additional Information – May 1, 2020 | 168 |
Total Brokerage Commissions | |||
Fund | 2019 | 2018 | 2017 |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $25,683 | $55,365 | $83,291 |
VP – American Century Diversified Bond Fund | 103,168 | 134,124 | 70,905 |
VP – Balanced Fund | 240,046 | 357,414 | 292,408 |
VP – BlackRock Global Inflation-Protected Securities Fund | 5,679 | 6,426 | 18,373 |
VP – Centersquare Real Estate Fund | 534,088 | 408,011 | 585,256 |
VP – Commodity Strategy Fund | 0 | 0 | 0 |
VP – Conservative Portfolio | 17,052 | 25,566 | 28,247 |
VP – Core Equity Fund | 82,779 | 96,300 | 117,119 |
VP – Disciplined Core Fund | 2,291,371 | 2,563,472 | 3,049,456 |
VP – Dividend Opportunity Fund | 525,851 | 1,664,257 | 1,085,806 |
VP – Emerging Markets Bond Fund | 2,074 | 1,446 | 790 |
VP – Emerging Markets Fund | 369,599 | 879,972 | 1,170,699 |
VP – Global Strategic Income Fund | 3,948 | 12,284 | 31,281 |
VP – Government Money Market Fund | 0 | 0 | 0 |
Statement of Additional Information – May 1, 2020 | 169 |
Total Brokerage Commissions | |||
Fund | 2019 | 2018 | 2017 |
VP – High Yield Bond Fund | $826 | $3,530 | $2,335 |
VP – Income Opportunities Fund | 599 | 4,234 | 2,300 |
VP – Intermediate Bond Fund | 445,121 | 300,320 | 298,808 |
VP – Large Cap Growth Fund | 320,535 | 266,935 | 418,568 |
VP – Large Cap Index Fund | 24,269 | 23,748 | 28,576 |
VP – Limited Duration Credit Fund | 65,357 | 46,576 | 54,273 |
VP – Loomis Sayles Growth Fund | 158,155 | 132,493 | 453,048 |
VP – Los Angeles Capital Large Cap Growth Fund | 292,162 | 414,032 | 676,838 |
VP – MFS Value Fund | 176,632 | 127,570 | 175,319 |
VP – Mid Cap Growth Fund | 0 | 35,607 | 451,753 |
VP – Moderate Portfolio | 165,258 | 355,664 | 385,408 |
VP – Moderately Aggressive Portfolio | 68,931 | 142,490 | 215,077 |
VP – Moderately Conservative Portfolio | 34,089 | 52,978 | 70,979 |
VP – Morgan Stanley Advantage Fund | 529,131 | 598,347 | 816,876 |
VP – MV Moderate Growth Fund | 1,116,642 | 1,457,422 | 1,435,381 |
VP – Overseas Core Fund | 969,462 | 2,113,982 | 679,748 |
VP – Partners Core Bond Fund | 0 | 0 | 1,050 |
VP – Partners Core Equity Fund | 393,893 | 423,723 | 408,242 |
VP – Partners International Core Equity Fund | 614,972 | 1,491,314 | 3,749,005 |
VP – Partners International Growth Fund | 724,438 | 728,210 | 1,142,296 |
VP – Partners International Value Fund | 156,462 | 355,236 | 306,378 |
VP – Partners Small Cap Growth Fund | 688,372 | 872,236 | 916,100 |
VP – Partners Small Cap Value Fund | 1,023,662 | 894,593 | 1,296,914 |
VP – Select Large Cap Equity Fund | 562,246 | 369,901(a) | N/A |
VP – Select Large Cap Value Fund | 187,473 | 207,447 | 208,766 |
VP – Select Mid Cap Value Fund | 100,092 | 272,119 | 219,357 |
VP – Select Small Cap Value Fund | 41,348 | 31,429 | 73,163 |
VP – Seligman Global Technology Fund | 57,073 | 35,421 | 78,188 |
VP – T. Rowe Price Large Cap Value Fund | 268,798 | 254,894 | 489,954 |
VP – TCW Core Plus Bond Fund | 58,859 | 70,515 | 51,446 |
VP – U.S. Government Mortgage Fund | 133,447 | 48,112 | 110,939 |
VP – Victory Sycamore Established Value Fund | 243,436 | 252,119 | 326,556 |
VP – Wells Fargo Short Duration Government Fund | 56,286 | 22,583 | 25,584 |
VP – Westfield Mid Cap Growth Fund | 382,305 | 415,697 | 362,194 |
(a) | For the period from January 4, 2018 (commencement of operations) to December 31, 2018. |
Statement of Additional Information – May 1, 2020 | 170 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
For Funds with fiscal period ending December 31 | ||
VP – Aggressive Portfolio | $0 | $0 |
VP – American Century Diversified Bond Fund | 0 | 0 |
VP – Balanced Fund | 419,214,627 | 70,563 |
VP – BlackRock Global Inflation-Protected Securities Fund | 0 | 0 |
VP – Centersquare Real Estate Fund | 312,582,002 | 80,209 |
VP – Commodity Strategy Fund | 0 | 0 |
VP – Conservative Portfolio | 0 | 0 |
VP – Core Equity Fund | 104,498,979 | 14,812 |
VP – Disciplined Core Fund | 2,933,295,018 | 415,210 |
VP – Dividend Opportunity Fund | 752,157,685 | 128,191 |
VP – Emerging Markets Bond Fund | 0 | 0 |
VP – Emerging Markets Fund | 97,374,011 | 106,014 |
VP – Global Strategic Income Fund | 0 | 0 |
VP – Government Money Market Fund | 0 | 0 |
VP – High Yield Bond Fund | 0 | 0 |
VP – Income Opportunities Fund | 0 | 0 |
VP – Intermediate Bond Fund | 0 | 0 |
VP – Large Cap Growth Fund | 1,019,842,268 | 119,345 |
VP – Large Cap Index Fund | 138,821 | 242 |
VP – Limited Duration Credit Fund | 0 | 0 |
VP – Loomis Sayles Growth Fund | 309,566,340 | 87,989 |
VP – Los Angeles Capital Large Cap Growth Fund | 2,663,821,555 | 58,432 |
VP – MFS Value Fund | 394,636,192 | 31,171 |
VP – Mid Cap Growth Fund | 0 | 0 |
VP – Moderate Portfolio | 0 | 0 |
VP – Moderately Aggressive Portfolio | 0 | 0 |
VP – Moderately Conservative Portfolio | 0 | 0 |
VP – Morgan Stanley Advantage Fund | 3,614,325,591 | 151,702 |
VP – MV Moderate Growth Fund | 90,422,544 | 16,656 |
Statement of Additional Information – May 1, 2020 | 171 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
VP – Overseas Core Fund | $447,831,809 | $277,683 |
VP – Partners Core Bond Fund | 0 | 0 |
VP – Partners Core Equity Fund | 831,346,906 | 56,198 |
VP – Partners International Core Equity Fund | 0 | 0 |
VP – Partners International Growth Fund | 252,601,040 | 222,601 |
VP – Partners International Value Fund | 0 | 0 |
VP – Partners Small Cap Growth Fund | 652,029,623 | 200,952 |
VP – Partners Small Cap Value Fund | 643,041,424 | 693,275 |
VP – Select Large Cap Equity Fund | 831,926,325 | 135,297 |
VP – Select Large Cap Value Fund | 166,957,756 | 50,034 |
VP – Select Mid Cap Value Fund | 135,214,477 | 30,697 |
VP – Select Small Cap Value Fund | 18,002,855 | 12,146 |
VP – Seligman Global Technology Fund | 42,666,108 | 13,690 |
VP – T. Rowe Price Large Cap Value Fund | 733,793,783 | 46,406 |
VP – TCW Core Plus Bond Fund | 0 | 0 |
VP – U.S. Government Mortgage Fund | 0 | 0 |
VP – Victory Sycamore Established Value Fund | 470,018,660 | 138,082 |
VP – Wells Fargo Short Duration Government Fund | 0 | 0 |
VP – Westfield Mid Cap Growth Fund | 454,146,839 | 101,772 |
Statement of Additional Information – May 1, 2020 | 172 |
Statement of Additional Information – May 1, 2020 | 173 |
Fund | Issuer |
Value of securities owned
at end of fiscal period |
VP – Dividend Opportunity Fund | Citigroup, Inc. | $40,743,900 |
JPMorgan Chase & Co. | $69,700,000 | |
Morgan Stanley | $12,524,400 | |
PNC Financial Services Group, Inc.(The) | $11,573,175 | |
VP – Emerging Markets Bond Fund | None | N/A |
VP – Emerging Markets Fund | None | N/A |
VP – Global Strategic Income Fund | Credit Suisse Mortgage Capital Certificates | $939,529 |
JPMorgan Chase Commercial Mortgage Securities Trust | $1,150,519 | |
VP – Government Money Market Fund | None | N/A |
VP – High Yield Bond Fund | None | N/A |
VP – Income Opportunities Fund | None | N/A |
VP – Intermediate Bond Fund | Citigroup Mortgage Loan Trust, Inc. | $39,129,683 |
Credit Suisse Mortgage Capital Certificates | $59,815,753 | |
Credit Suisse Mortgage Trust | $5,426,723 | |
JPMorgan Chase & Co. | $19,888,658 | |
JPMorgan Resecuritization Trust | $317,002 | |
Morgan Stanley | $8,564,212 | |
Morgan Stanley Capital I Trust | $12,774,909 | |
The Goldman Sachs Group, Inc. | $9,866,876 | |
VP – Large Cap Growth Fund | Citigroup, Inc. | $24,425,169 |
VP – Large Cap Index Fund | Ameritrade | $949,339 |
Citigroup, Inc. | $7,843,041 | |
E*TRADE Financial Corp. | $461,050 | |
Franklin Resources, Inc. | $325,737 | |
JPMorgan Chase & Co. | $19,660,976 | |
Morgan Stanley | $2,827,549 | |
PNC Financial Services Group, Inc.(The) | $3,145,190 | |
Raymond James & Associates | $496,324 | |
The Charles Schwab Corp. | $2,444,822 | |
The Goldman Sachs Group, Inc. | $3,294,207 | |
VP – Limited Duration Credit Fund | Goldman Sachs Group | $9,758,488 |
VP – Loomis Sayles Growth Fund | None | N/A |
VP – Los Angeles Capital Large Cap Growth Fund | Eaton Vance Corp. | $5,032,248 |
VP – MFS Value Fund | Citigroup, Inc. | $39,779,228 |
The Goldman Sachs Group, Inc. | $25,886,209 | |
JPMorgan Chase & Co. | $77,345,811 | |
PNC Financial Services Group, Inc.(The) | $23,071,005 | |
VP – Mid Cap Growth Fund | Raymond James Financial, Inc. | $10,685,997 |
VP – Moderate Portfolio | None | N/A |
VP – Moderately Aggressive Portfolio | None | N/A |
VP – Moderately Conservative Portfolio | None | N/A |
VP – Morgan Stanley Advantage Fund | None | N/A |
VP – MV Moderate Growth Fund | Citigroup, Inc. | $807,238 |
The Goldman Sachs Group, Inc. | $637,646 | |
JPMorgan Chase & Co. | $1,662,395 | |
Morgan Stanley | $429,681 | |
VP – Overseas Core Fund | None | N/A |
Statement of Additional Information – May 1, 2020 | 174 |
Fund | Issuer |
Value of securities owned
at end of fiscal period |
VP – Partners Core Bond Fund | Bear Stearns Adjustable Rate Mortgage Trust | $271,293 |
Bear Stearns Alt-A Trust | $102,608 | |
Bear Stearns Asset-Backed Securities Trust | $253,675 | |
Bear Stearns Commercial Mortgage Securities Trust | $5,632 | |
Chase Funding Trust | $1,256,791 | |
Chase Mortgage Finance Corp. | $602,378 | |
Citigroup Commercial Mortgage Trust | $1,660,912 | |
Citigroup Mortgage Loan Trust, Inc. | $479,990 | |
Citigroup, Inc. | $11,003,748 | |
Citigroup/Deutsche Bank Commercial Mortgage Trust | $2,140 | |
Credit Suisse Commercial Mortgage Trust | $2,584,635 | |
Credit Suisse First Boston Mortgage Securities Corp. | $110,938 | |
Credit Suisse First Boston Mortgage-Backed Pass-Through Certificates | $523,646 | |
Credit Suisse Group AG | $2,297,091 | |
Credit Suisse Group Funding Guernsey Ltd. | $1,210,732 | |
Credit Suisse Mortgage Capital Certificates | $2,943,458 | |
GS Mortgage Securities Corp. II | $2,044,738 | |
GS Mortgage Securities Trust | $14,935,690 | |
JPMorgan Chase & Co. | $13,301,057 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $398,561 | |
JPMorgan Mortgage Trust | $509,612 | |
LB-UBS Commercial Mortgage Trust | $207 | |
Merrill Lynch Mortgage Trust | $1,335,442 | |
Merrill Lynch/Countrywide Commercial Mortgage Trust | $3 | |
Morgan Stanley | $16,859,494 | |
Morgan Stanley Bank of America Merrill Lynch Trust | $911,918 | |
Morgan Stanley Capital I Trust | $1,796,271 | |
Morgan Stanley Mortgage Loan Trust | $258,634 | |
PNC Bank NA | $582,936 | |
The Charles Schwab Corp. | $2,880,208 | |
The Goldman Sachs Group, Inc. | $13,757,535 | |
VP – Partners Core Equity Fund | E*TRADE Financial Corp. | $2,690,441 |
JPMorgan Chase & Co. | $25,025,785 | |
Morgan Stanley | $15,226,859 | |
PNC Financial Services Group, Inc.(The) | $20,047,134 | |
Raymond James Financial, Inc. | $3,399,480 | |
VP – Partners International Core Equity Fund | None | N/A |
VP – Partners International Growth Fund | None | N/A |
VP – Partners International Value Fund | Credit Suisse Group AG | $2,716,310 |
VP – Partners Small Cap Growth Fund | Primerica, Inc. | $1,800,945 |
Stifel Financial Corp. | $1,837,695 | |
VP – Partners Small Cap Value Fund | Piper Jaffray Companies | $2,691,660 |
VP – Select Large Cap Equity Fund | Citigroup, Inc. | $30,277,431 |
JPMorgan Chase & Co. | $37,194,429 |
Statement of Additional Information – May 1, 2020 | 175 |
Fund | Issuer |
Value of securities owned
at end of fiscal period |
VP – Select Large Cap Value Fund | Citigroup, Inc. | $49,843,371 |
JPMorgan Chase & Co. | $50,281,580 | |
Morgan Stanley | $34,884,288 | |
VP – Select Mid Cap Value Fund | None | N/A |
VP – Select Small Cap Value Fund | None | N/A |
VP – Seligman Global Technology Fund | None | N/A |
VP – T. Rowe Price Large Cap Value Fund | Citigroup, Inc. | $11,864,464 |
Franklin Resources, Inc. | $8,049,409 | |
JPMorgan Chase & Co. | $77,392,928 | |
Morgan Stanley | $46,997,121 | |
VP – TCW Core Plus Bond Fund | Citigroup Mortgage Loan Trust, Inc. | $1,875,430 |
Credit Suisse First Boston Mortgage-Backed Pass-Through Certificates | $874,155 | |
Credit Suisse Mortgage Capital Certificates | $6,358,142 | |
GS Mortgage-Backed Securities Trust | $11,246,513 | |
JPMorgan Chase & Co. | $9,479,719 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $2,846,051 | |
JPMorgan Mortgage Acquisition Corp | $9,975,022 | |
Merrill Lynch | $1,640,923 | |
Merrill Lynch First Franklin Mortgage Loan Trust | $3,166,111 | |
Morgan Stanley Mortgage Loan Trust | $1,269,785 | |
Raymond James Financial, Inc. (subsidiary) | $2,578,442 | |
The Goldman Sachs Group, Inc. | $6,551,912 | |
VP – U.S. Government Mortgage Fund | Citigroup Mortgage Loan Trust, Inc. | $8,626,618 |
Credit Suisse Mortgage Capital Certificates | $1,593,903 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $7,915,740 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $153,959 | |
Morgan Stanley Capital I, Inc. | $2,847,295 | |
VP – Victory Sycamore Established Value Fund | E*TRADE Financial Corp. | $10,804,865 |
VP – Wells Fargo Short Duration Government Fund | GS Mortgage Securities Trust | $1,456,772 |
GS Mortgage Securities Corp. Trust | $276,976 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $716,445 | |
Morgan Stanley Capital I Trust | $81,954 | |
VP – Westfield Mid Cap Growth Fund | None | N/A |
Statement of Additional Information – May 1, 2020 | 176 |
Statement of Additional Information – May 1, 2020 | 177 |
■ | For equity, alternative and flexible funds (other than the equity funds identified below) and funds-of-funds (equity and fixed income), a complete list of Fund portfolio holdings as of month-end is posted approximately, but no earlier than, 15 calendar days after such month-end. |
■ | For Columbia Small Cap Growth Fund I and Columbia Variable Portfolio – Small Company Growth Fund, a complete list of Fund portfolio holdings as of month-end is posted approximately, but no earlier than, 30 calendar days after such month-end. |
■ | For fixed-income Funds (other than money market funds), a complete list of Fund portfolio holdings as of calendar quarter-end is posted approximately, but no earlier than, 30 calendar days after such quarter-end. |
■ | For money market Funds, a complete list of Fund portfolio holdings as of month-end is posted no later than five business days after such month-end. Such month-end holdings are continuously available on the website for at least six months, together with a link to an SEC webpage where a user of the website may obtain access to the Fund’s most recent 12 months of publicly available filings on Form N-MFP. Money market Fund portfolio holdings information posted on the website, at minimum, includes with respect to each holding, the name of the issuer, the category of investment (e.g., Treasury debt, government agency debt, asset backed commercial paper, structured investment vehicle note), the CUSIP number (if any), the principal amount, the maturity date (as determined under Rule 2a-7 for purposes of calculating weighted average maturity), |
Statement of Additional Information – May 1, 2020 | 178 |
the final maturity date (if different from the maturity date previously described), coupon or yield and the value. The money market Funds will also disclose on the website its overall weighted average maturity, weighted average life maturity, percentage of daily liquid assets, percentage of weekly liquid assets and daily inflows and outflows. |
Statement of Additional Information – May 1, 2020 | 179 |
Statement of Additional Information – May 1, 2020 | 180 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency of
Disclosure |
||
Catapult ME, Inc. | Used for commercial printing. | As Needed | ||
Citigroup, Inc. | Used for mortgage decision support. | Daily | ||
Compliance Solutions Strategies LLC | Used to report returns and analytics to client facing materials. | Monthly | ||
Curtis 1000 | Used for commercial printing. | As Needed | ||
Donnelley Financial Solutions | Used to provide Edgar filing and typesetting services, and printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
DS Graphics, Inc. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Elevation Exhibits & Events | Used for trade show exhibits. | As Needed | ||
Equifax, Inc. | Used to ensure that Columbia Management does not violate the Office of Foreign Assets Control (OFAC) sanction requirements. | Daily | ||
Ernst & Young, LLP | Used to analyze PFIC investments. | Monthly | ||
Eze Software Group, LLC | Used to facilitate the evaluation of commission rates and to provide flexible commission reporting. | Daily | ||
FactSet Research Systems, Inc. | Used to calculate portfolio performance attribution, portfolio analytics, data for fundamental research, and general market news and analysis. | Daily | ||
Fidelity National Information Services, Inc. | Used as portfolio accounting system. | Daily | ||
Goldman Sachs Asset Management, L.P., as agent to KPMG LLP | Holdings by Columbia Contrarian Core Fund and Columbia High Yield Bond Fund in certain audit clients of KPMG LLP to assist the accounting firm in complying with its regulatory obligations relating to independence of its audit clients. | Monthly | ||
Harte-Hanks, Inc. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
IHS Markit, Ltd. | Used for an asset database for analytics and investor reporting. | As Needed | ||
Imagine! Print Solutions | Used for commercial printing. | As Needed | ||
Institutional Shareholder Services Inc. (ISS) | Used for proxy voting administration and research on proxy matters. | Daily | ||
Intex Solutions Inc. | Used to provide mortgage analytics. | Periodic | ||
Investment Company Institute (ICI) | Disclosure of Form N-PORT data. | As Needed | ||
Investment Technology Group, Inc. | Used to evaluate and assess trading activity, execution and practices. | Quarterly | ||
Investortools, Inc. | Used for municipal bond analytics, research and decision support. | As Needed | ||
JDP Marketing Services | Used to write or edit Columbia Fund shareholder reports, quarterly fund commentaries, and communications, including shareholder letters and management’s discussion of Columbia Fund performance. | As Needed | ||
John Roberts, Inc. | Used for commercial printing. | As Needed |
Statement of Additional Information – May 1, 2020 | 181 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency of
Disclosure |
||
Kendall Press | Used for commercial printing. | As Needed | ||
KPMG US LLP | Used to provide tax services. | Daily | ||
Kynex, Inc. | Used to provide portfolio attribution reports for the Columbia Convertible Securities Fund. Used also for portfolio analytics. | Daily | ||
Malaspina Communications, LLC | Used to facilitate writing management’s discussion of Columbia Fund performance for Columbia Fund shareholder reports and periodic marketing communications. | Monthly | ||
Merrill Corporation | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Morningstar Investment Services, LLC | Used for independent research and ranking of funds. Used also for statistical analysis. | As Needed | ||
MSCI, Inc. | Used as a hosted risk analytics platform designed for research, investment oversight and strategy development. | Daily | ||
NASDAQ | Used to evaluate and assess trading activity, execution and practices. | Daily | ||
R. R. Donnelley & Sons Co. | Used to provide printing prospectuses, factsheets, annual and semi-annual reports. Used for commercial printing. | As Needed | ||
RegEd, Inc. | Used to review external and certain internal communications prior to dissemination. | Daily | ||
Sustainalytics US, Inc. | Used for reviewing the impact of Columbia U.S. Social Bond Fund's municipal investments and providing ESG ratings. | Quarterly | ||
S.W.I.F.T. Scrl. | Used to send trade messages via SWIFT to custodians. | Daily | ||
Thomson Reuters Corp. | Used for statistical analysis. | As Needed | ||
Visions, Inc. | Used for commercial printing. | As Needed | ||
Wilshire Associates, Inc. | Used to provide performance attribution reporting. | Daily |
Statement of Additional Information – May 1, 2020 | 182 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency of
Disclosure |
||
Recipients under arrangements with subadvisers: | ||||
AccuSource LLC | Used by certain subadvisers for custodian reconciliation. | Daily | ||
Ashland Partners & Co. LLP | Used by certain subadvisers for audit and Global Investment Performance Standards (GIPS) evaluation. | Annually | ||
Axioma, Inc. | Used by certain subadvisers for analytics and attribution analysis. | Daily | ||
BlackRock, Inc. | Used by certain subadvisers for analytical and statistical information. | Daily | ||
Bloomberg Finance L.P. | Used by certain subadvisers for trade management/compliance. Used by certain subadvisers for analytical and statistical information. Used by certain subadvisers for analytical, portfolio management, and statistical information. Used by certain subadvisers for analytics, risk, attribution and client reporting. | Daily | ||
BNY Mellon Corp. | Used by certain subadvisers for fund accounting and middle-office functions. | Daily | ||
Brown Brothers Harriman & Co. | Used by certain subadvisers for electronic trade transmission and settlement. | Daily | ||
Citibank N.A. | Used by certain subadvisers for middle office functions. | Daily | ||
Clearwater Analytics, LLC | Used by certain subadvisers for client reporting. | Daily | ||
Eagle Investment Systems, LLC | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Electra Information Systems, Inc. | Used by certain subadvisers for electronic reconciliations of portfolio holdings. | Daily or Monthly | ||
Euronext N.V. | Used by certain subadvisers for operational efficiency. | Daily | ||
eVestment Alliance, LLC | Used by certain subadvisers for updating databases. | Quarterly | ||
FactSet Research Systems, Inc. | Used by certain subadvisers for analytical and statistical information. | Daily | ||
Fidelity Corporate Actions Solutions, Inc. | Used by certain subadvisers for corporate actions management. | Daily | ||
Financial Recovery Technologies LLC | Used by certain subadvisers for class action monitoring services. | Quarterly | ||
Financial Tracking Technologies LLC | Used by certain subadvisers for compliance monitoring. | Daily | ||
FX Connect, LLC | Used by certain subadvisers for foreign exchange derivatives reconciliation. | Daily | ||
FX Transparency LLC | Used by certain subadvisers for foreign exchange trade cost analysis. | Quarterly | ||
Global Trading Analytics, LLC | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily | ||
Goldman Sachs & Co. | Used by certain subadvisers for clearing treasury futures and swaps. | Daily |
Statement of Additional Information – May 1, 2020 | 183 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency of
Disclosure |
||
ICE Data Services Inc. | Used by certain subadvisers for liquidity reporting. Used by certain subadvisers for data and pricing. | Daily | ||
IHS Markit Ltd. | Used by certain subadvisers for confirmation and settlement of bank loan trades. Used by certain subadvisers for transaction cost analysis and other analytics. Used by certain subadvisers for matching credit default swaps and interest rate swaps. | Daily | ||
Infinit-O Global, Ltd. | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Institutional Shareholder Services, Inc. | Used by certain subadvisers for proxy voting administration and research services. | Daily | ||
LiquidNet, Inc. | Used by certain subadvisers for commission tracking. | Daily | ||
MSCI Barra Inc. | Used by certain subadvisers for analytical and statistical information. | Daily or Monthly | ||
Nex Group plc | Used by certain subadvisers for daily reconciliations on collateral management. | Daily | ||
Omgeo LLC | Used by certain subadvisers for trade execution and SWIFT transactions. Used by certain subadvisers for analytics. | Daily | ||
S&P Global Corp. | Used by certain subadvisers for market data. | Daily | ||
Schwab Compliance Technologies, Inc. | Used by certain subadvisers for compliance and personal trade monitoring. | Daily | ||
SEI Investments Co. | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Seismic Software, Inc. | Used by certain subadvisers to automate quarterly updates. | Quarterly | ||
SS&C Technologies, Inc. | Used by certain subadvisers for portfolio accounting systems. Used by certain subadvisers for SWIFT messages from custodians to facilitate automated reconciliation. | Daily | ||
State Street Bank and Trust Company | Used by certain subadvisers for middle office functions. | Daily or Monthly | ||
State Street Corp. | Used by certain subadvisers for order management and compliance. | Daily | ||
STP Investment Services, LLC | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Trade Informatics LLC | Used by certain subadvisers for transaction cost analysis and other analytics. Used by certain subadvisers for asset allocation. | Daily | ||
Tradeweb Markets LLC | Used by certain subadvisers for confirming TBAs, treasuries and discount notes. | Daily | ||
VERMEG Co. | Used by certain subadvisers for the management of swap counterparty exposure. | Daily |
Statement of Additional Information – May 1, 2020 | 184 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency of
Disclosure |
||
Virtu ITG LLC | Used by certain subadvisers for transaction cost analysis and other analytics. Used by certain subadvisers for portfolio analytics, compliance monitoring, trading and recordkeeping system purposes. | Daily or Monthly |
■ | Allianz Life Insurance Company of North America |
■ | Allianz Life Insurance Company of New York |
■ | American General Life Insurance Company |
■ | American United Life Insurance Company |
■ | Ameritas Life Insurance Corp |
■ | Ameritas Life Insurance Corp of New York |
■ | Delaware Life Insurance Co of New York |
■ | Delaware Life Insurance Company |
■ | Equitrust Life Insurance Company |
■ | Farm, Bureau Life Insurance Company |
■ | Genworth Life & Annuity Insurance |
■ | Genworth Life Insurance Company of New York |
■ | Great West Life & Annuity Company |
■ | Great West Life & Annuity Company of New York |
■ | Guardian Insurance & Annuity Company |
■ | Independence Life & Annuity Co |
■ | Integrity Life Insurance Company |
■ | Jefferson National Life Insurance Company |
■ | Jefferson National Life Insurance Company of New York |
■ | Liberty Life Assurance Company |
Statement of Additional Information – May 1, 2020 | 185 |
■ | Lincoln Life & Annuity Company of New York |
■ | MEMBERS Life Insurance Company/CUNA |
■ | Midland National Life Insurance Company |
■ | National Integrity Life Insurance Company |
■ | Nationwide Financial Services, Inc. |
■ | New York Life Insurance & Annuity Corporation |
■ | Principal Life Insurance Company |
■ | Principal National Life Insurance Company |
■ | Prudential Annuities Life Assurance Corporation |
■ | RiverSource Life Insurance Company* |
■ | RiverSource Life Insurance Co. of New York* |
■ | Security Benefit Life Insurance |
■ | Symetra Life Insurance Company |
■ | The Lincoln National Life Insurance Company |
■ | The United States Life Insurance Company in the City of New York |
■ | Transamerica Life Insurance Company |
■ | Transamerica Financial Life Insurance Company |
■ | Transamerica Advisors Life Insurance Company |
■ | Transamerica Advisors Life Insurance Company of New York |
■ | Transamerica Premier Life Insurance Company |
■ | Voya Insurance & Annuity Company |
■ | Voya Retirement Insurance & Annuity Company |
* | Ameriprise Financial affiliate |
Statement of Additional Information – May 1, 2020 | 186 |
Statement of Additional Information – May 1, 2020 | 187 |
Statement of Additional Information – May 1, 2020 | 188 |
Statement of Additional Information – May 1, 2020 | 189 |
Statement of Additional Information – May 1, 2020 | 190 |
Statement of Additional Information – May 1, 2020 | 194 |
Statement of Additional Information – May 1, 2020 | 195 |
Statement of Additional Information – May 1, 2020 | 196 |
Fund |
Total
Capital Loss Carryovers |
Amount not Expiring | |
Short-term | Long-term | ||
For Funds with fiscal period ending December 31 | |||
VP – American Century Diversified Bond Fund | $38,307,572 | $0 | $38,307,572 |
VP – Commodity Strategy Fund | $280,316 | $280,316 | $0 |
VP – Emerging Markets Bond Fund | $15,139,114 | $3,384,809 | $11,754,305 |
VP – Global Strategic Income Fund | $5,846,201 | $1,832,667 | $4,013,534 |
VP – High Yield Bond Fund | $4,414,700 | $954,578 | $3,460,122 |
VP – Income Opportunities Fund | $5,332,722 | $1,973,820 | $3,358,902 |
VP – Limited Duration Credit Fund | $31,122,110 | $13,931,042 | $17,191,068 |
VP – Partners International Value Fund | $2,016,658 | $0 | $2,016,658 |
Statement of Additional Information – May 1, 2020 | 197 |
Statement of Additional Information – May 1, 2020 | 198 |
Statement of Additional Information – May 1, 2020 | 199 |
Statement of Additional Information – May 1, 2020 | 200 |
Statement of Additional Information – May 1, 2020 | 201 |
Statement of Additional Information – May 1, 2020 | 202 |
Statement of Additional Information – May 1, 2020 | 203 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
VP – Aggressive Portfolio |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.74% | 94.96% |
Class 4 | 93.92% | |||
Class 1 | 99.90% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 4
|
6.08% | N/A | |
VP – American Century Diversified Bond Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 83.11% (a) |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
40.09% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
12.02% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
9.52% | N/A |
Statement of Additional Information – May 1, 2020 | 204 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.08% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
16.89% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.98% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.00% | N/A | |
VP – Balanced Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2
|
100.00% | N/A(a) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1
|
99.60% | 93.41% | |
Class 3 | 93.40% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
6.60% | N/A | |
VP – BlackRock Global Inflation-Protected Securities Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 1
|
38.86% | N/A(a) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1
|
39.61% | 93.86% | |
Class 2 | 92.09% | |||
Class 3 | 94.28% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1
|
21.53% | N/A | |
Class 2 | 7.85% | |||
Class 3 | 5.72% | |||
VP – CenterSquare Real Estate Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 87.26% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.85% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
50.53% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
30.09% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.13% | N/A |
Statement of Additional Information – May 1, 2020 | 205 |
Statement of Additional Information – May 1, 2020 | 206 |
Statement of Additional Information – May 1, 2020 | 207 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
9.94% | N/A | |
NEW YORK LIFE INSURANCE & ANNUITY
CORP ATTN CHRISTINE DEMPSEY 169 LACKAWANNA AVE PARSIPPANY NJ 07054-1007 |
Class 2
|
88.23% | 46.25% | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.63% | N/A | |
VP – Emerging Markets Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 35.38% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.92% | N/A | |
JPMCB NA CUST FOR
VP CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.76% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
51.48% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
23.37% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.93% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.28% | 61.03% | |
Class 3 | 94.56% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
5.44% | N/A | |
VP – Global Strategic Income Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 1
|
100.00% | N/A(a) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.00% | 94.25% | |
Class 3 | 94.29% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.90% | N/A | |
Class 3 | 5.71% | |||
VP – Government Money Market Fund |
DELAWARE LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1
|
21.84% | N/A |
Statement of Additional Information – May 1, 2020 | 208 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR
VP CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
18.03% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
33.69% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
16.93% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
89.01% | 70.83% | |
Class 3 | 93.30% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
10.97% | N/A | |
Class 3 | 6.70% | |||
VP – High Yield Bond Fund |
MIDLAND NATIONAL LIFE INS CO
4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2
|
6.94% | N/A |
NATIONWIDE LIFE INSURANCE COMPANY
C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class 2
|
13.26% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1
|
99.97% | 91.57% | |
Class 2 | 75.48% | |||
Class 3 | 95.53% | |||
VP – Income Opportunities Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 41.11% (a) |
DELAWARE LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
7.55% | N/A | |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.04% | N/A | |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
15.85% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
34.00% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.10% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
7.04% | N/A |
Statement of Additional Information – May 1, 2020 | 209 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
81.69% | 45.30% | |
Class 3 | 94.61% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
9.34% | N/A | |
Class 3 | 5.39% | |||
VP – Intermediate Bond Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 75.81% (a) |
JPMCB NA CUST FOR
VP CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.50% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
36.11% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
12.43% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
8.75% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.53% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
18.56% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.01% | N/A | |
Class 3 | 94.41% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.97% | N/A | |
Class 3 | 5.59% | |||
VP – Large Cap Growth Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 71.78% (a) |
DELAWARE LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
44.17% | N/A | |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.73% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
24.00% | N/A |
Statement of Additional Information – May 1, 2020 | 210 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
14.21% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
21.42% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
22.31% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
48.34% | N/A | |
Class 3 | 96.33% | |||
VP – Large Cap Index Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 48.89% (a) |
DELAWARE LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
91.11% | N/A | |
DELAWARE LIFE INSURANCE COMPANY
OF NEW YORK 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
8.84% | N/A | |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
65.60% | N/A | |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
29.54% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
90.52% | 43.19% | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
9.48% | N/A | |
VP – Limited Duration Credit Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 78.48% (a) |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
21.85% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
8.65% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
7.68% | N/A |
Statement of Additional Information – May 1, 2020 | 211 |
Statement of Additional Information – May 1, 2020 | 212 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.39% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
27.41% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
16.24% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
20.63% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
22.04% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.96% | N/A | |
VP – MFS Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 88.56% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
8.01% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
33.87% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
19.81% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
15.44% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
15.79% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.18% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.81% | N/A |
Statement of Additional Information – May 1, 2020 | 213 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
VP – Mid Cap Growth Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 38.85% (a) |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
43.60% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
45.62% | N/A | |
KANSAS CITY LIFE INS
ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2
|
14.58% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
81.83% | 52.42% | |
Class 3 | 94.04% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
5.96% | N/A | |
TALCOTT RESOLUTION LIFE INSURANCE
COMPANY PO BOX 5051 HARTFORD CT 06102-5051 |
Class 1
|
5.01% | N/A | |
VP – Moderate Portfolio |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.00% | 94.11% |
Class 4 | 94.20% | |||
Class 1 | 98.88% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.00% | N/A | |
Class 4 | 5.80% | |||
VP – Moderately Aggressive Portfolio |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.57% | 94.32% |
Class 4 | 93.99% | |||
Class 1 | 98.50% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.43% | N/A | |
Class 4 | 6.01% | |||
VP – Moderately Conservative Portfolio |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.86% | 93.92% |
Class 4 | 93.99% | |||
Class 1 | 37.82% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.14% | N/A | |
Class 4 | 6.01% | |||
Class 1 | 61.68% | |||
VP – Morgan Stanley Advantage Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 93.25% (a) |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.43% | N/A |
Statement of Additional Information – May 1, 2020 | 214 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.27% | N/A | |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.20% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
22.40% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.41% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
17.73% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
18.84% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
97.05% | N/A | |
VP – MV Moderate Growth Fund |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1
|
99.07% | 93.34% |
Class 2 | 93.34% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.66% | N/A | |
VP – Overseas Core Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 73.83% (a) |
DELAWARE LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
9.63% | N/A | |
GE LIFE & ANNUITY ASSURANCE CO
ATTN VARIABLE ACCOUNTING 6610 W BROAD ST BLDG 3 5TH FL RICHMOND VA 23230-1702 |
Class 2
|
23.70% | N/A | |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.51% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
50.30% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
27.96% | N/A |
Statement of Additional Information – May 1, 2020 | 215 |
Statement of Additional Information – May 1, 2020 | 216 |
Statement of Additional Information – May 1, 2020 | 217 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
VP – Partners International Growth Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 90.42% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.46% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
22.71% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.07% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
26.94% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
25.32% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.66% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.33% | N/A | |
VP – Partners International Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 91.06% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.56% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
22.49% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.79% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
26.44% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
24.91% | N/A |
Statement of Additional Information – May 1, 2020 | 218 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.28% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.71% | N/A | |
VP – Partners Small Cap Growth Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 86.38% (a) |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
24.16% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.35% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
25.79% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
26.78% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
87.61% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
12.37% | N/A | |
VP – Partners Small Cap Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 73.95% (a) |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
25.09% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.93% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
24.25% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
25.73% | N/A |
Statement of Additional Information – May 1, 2020 | 219 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
91.12% | N/A | |
Class 3 | 94.91% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
8.84% | N/A | |
Class 3 | 5.09% | |||
VP – Select Large Cap Equity Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2
|
100.00% | 93.61% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
9.39% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
36.08% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
21.46% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.14% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.53% | N/A | |
VP – Select Large Cap Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 89.76% (a) |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.14% | N/A | |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.73% | N/A | |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.95% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
27.78% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
16.11% | N/A |
Statement of Additional Information – May 1, 2020 | 220 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
12.23% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
12.29% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
92.70% | N/A | |
Class 3 | 97.09% | |||
VP – Select Mid Cap Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 62.59% (a) |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
44.01% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
47.14% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.83% | 30.03% | |
Class 3 | 95.87% | |||
VP – Select Small Cap Value Fund |
AMERITAS LIFE INSURANCE CORP
5900 O ST LINCOLN NE 68510-2234 |
Class 2
|
27.79% | N/A |
GREAT-WEST LIFE & ANNUITY
FBO TRILLIUM VARIABLE ANNUITY ACCT 8515 E ORCHARD RD 2T2 GREENWOOD VLG CO 80111-5002 |
Class 1
|
23.42% | N/A | |
JEFFERSON NATL LIFE
10350 ORMSBY PARK PL STE 600 LOUISVILLE KY 40223-6175 |
Class 1
|
62.35% | N/A | |
KANSAS CITY LIFE INS
ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2
|
13.52% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
53.61% | 76.78% | |
Class 3 | 94.95% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
5.05% | N/A | |
TRANSAMERICA LIFE INSURANCE CO
4333 EDGEWOOD RD NE CEDAR RAPIDS IA 52499-0001 |
Class 1
|
6.60% | N/A | |
VP – Seligman Global Technology Fund |
AMERITAS LIFE INSURANCE CORP
5900 O ST LINCOLN NE 68510-2234 |
Class 2
|
5.64% | N/A |
Statement of Additional Information – May 1, 2020 | 221 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
GREAT-WEST LIFE & ANNUITY
FBO TRILLIUM VARIABLE ANNUITY ACCT 8515 E ORCHARD RD 2T2 GREENWOOD VLG CO 80111-5002 |
Class 1
|
95.36% | 58.05% | |
Class 2 | 29.65% | |||
JEFFERSON NATL LIFE
10350 ORMSBY PARK PL STE 600 LOUISVILLE KY 40223-6175 |
Class 2
|
35.60% | N/A | |
KANSAS CITY LIFE INS
ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2
|
12.66% | N/A | |
MIDLAND NATIONAL LIFE INS CO
4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2
|
5.74% | N/A | |
VP – T. Rowe Price Large Cap Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 90.55% (a) |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.81% | N/A | |
JPMCB NA CUST FOR
VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.05% | N/A | |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.62% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
26.75% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
15.87% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.73% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
12.25% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
91.98% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
8.01% | N/A | |
VP – TCW Core Plus Bond Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 81.51% (a) |
Statement of Additional Information – May 1, 2020 | 222 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
35.32% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.80% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
8.75% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
7.82% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
23.19% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.92% | N/A | |
VP – U.S. Government Mortgage Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 72.11% (a) |
DELAWARE LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
30.53% | N/A | |
JPMCB NA CUST FOR
VP CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.57% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
32.72% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.60% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
7.42% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
24.60% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
57.38% | N/A | |
Class 3 | 94.30% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
5.70% | N/A |
Statement of Additional Information – May 1, 2020 | 223 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage of Fund
(if greater than 25%) |
VP – Victory Sycamore Established Value Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 76.24% (a) |
JPMCB NA CUST FOR
VP AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
5.25% | N/A | |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
22.45% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
13.61% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
26.14% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
25.86% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.29% | N/A | |
Class 3 | 97.35% | |||
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.71% | N/A | |
VP – Wells Fargo Short Duration Government Fund |
COLUMBIA MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 89.10% (a) |
JPMCB NA CUST FOR
VP MODERATE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
65.91% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
6.84% | N/A | |
JPMCB NA CUST FOR
VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
7.47% | N/A | |
JPMCB NA CUST FOR VARIABLE
PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1
|
11.31% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
89.11% | N/A | |
RIVERSOURCE LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
10.86% | N/A |
Statement of Additional Information – May 1, 2020 | 224 |
(a) | Combination of all share classes of Columbia Management initial capital and/or affiliated funds-of-funds’ investments. |
Statement of Additional Information – May 1, 2020 | 225 |
Statement of Additional Information – May 1, 2020 | 226 |
Statement of Additional Information – May 1, 2020 | A-1 |
Statement of Additional Information – May 1, 2020 | A-2 |
Statement of Additional Information – May 1, 2020 | A-3 |
Long-Term Rating | Short-Term Rating |
AAA | F1+ |
AA+ | F1+ |
AA | F1+ |
AA– | F1+ |
A+ | F1 or F1+ |
A | F1 or F1+ |
A– | F2 or F1 |
BBB+ | F2 or F1 |
BBB | F3 or F2 |
BBB– | F3 |
BB+ | B |
BB | B |
BB– | B |
B+ | B |
B | B |
B– | B |
CCC+ / CCC / CCC– | C |
CC | C |
C | C |
RD / D | RD / D |
Statement of Additional Information – May 1, 2020 | A-4 |
Statement of Additional Information – May 1, 2020 | A-5 |
■ | There is a missed interest payment, principal payment, or preferred dividend payment, as applicable, on a rated obligation which is unlikely to be recovered. |
■ | The rated entity files for protection from creditors, is placed into receivership, or is closed by regulators such that a missed payment is likely to result. |
■ | The rated entity seeks and completes a distressed exchange, where existing rated obligations are replaced by new obligations with a diminished economic value. |
Statement of Additional Information – May 1, 2020 | A-6 |
■ | There is a missed interest payment, principal payment, or preferred dividend payment, as applicable, on a rated obligation which is unlikely to be recovered. |
■ | The rated entity files for protection from creditors, is placed into receivership, or is closed by regulators such that a missed payment is likely to result. |
■ | The rated entity seeks and completes a distressed exchange, where existing rated obligations are replaced by new obligations with a diminished economic value. |
Statement of Additional Information – May 1, 2020 | A-7 |
Statement of Additional Information – May 1, 2020 | B-1 |
■ | effectively exercise their voting rights across the full range of business normally associated with general meetings of a company in line with market best practice (e.g. the election of individual directors, discharge authorities, capital authorities, auditor appointment, major or related party transactions etc). |
■ | place items on the agenda of general meetings, and to propose resolutions subject to reasonable limitations; |
■ | call a meeting of shareholders for the purpose of transacting the legitimate business of the company; and |
■ | Clear, consistent and effective reporting to shareholders is undertaken at regular intervals and that they remain aware of shareholder sentiment on major issues to do with the business, its strategy and performance. Where significant shareholder dissent is emerging or apparent (e.g. through the voting levels seen at General Meetings), boards should act to address that. |
■ | Boards should also allow a reasonable opportunity for the shareholders at a general meeting to ask questions about or make comments on the management of the company, and to ask the external auditor questions related to the audit. |
Statement of Additional Information – May 1, 2020 | B-2 |
Statement of Additional Information – May 1, 2020 | B-3 |
■ | subject to proper oversight by the board and regular review (e.g. audit, shareholder approval); |
■ | clearly justified and not be detrimental to the long-term interests of the company; |
■ | undertaken in the normal course of business; |
■ | undertaken on fully commercial terms; |
■ | In line with best practice; and |
■ | In the interests of all shareholders. |
Statement of Additional Information – May 1, 2020 | B-4 |
Statement of Additional Information – May 1, 2020 | B-5 |
1. | Clear, simple and understandable; |
2. | Balanced and proportionate, in respect of structure, deliverables, opportunity and the market; |
3. | Aligned with the long-term strategy, related key performance indicators and risk management discipline; |
4. | Linked robustly to the delivery of performance; |
5. | Delivering outcomes that reflect value creation and the shareholder ‘experience’; and |
6. | Structured to avoid pay for failure or the avoidance of accountability to shareholders. |
Statement of Additional Information – May 1, 2020 | B-6 |
Statement of Additional Information – May 1, 2020 | B-7 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(a)(1) | Amendment No. 1 to the Agreement and Declaration of Trust effective September 11, 2007 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Registration Statement on Form N-1A | (a)(1) | 9/28/2007 |
(a)(2) | Amendment No. 2 to the Agreement and Declaration of Trust effective April 9, 2008 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #2 on Form N-1A | (a)(2) | 4/21/2008 |
(a)(3) | Amendment No. 3 to the Agreement and Declaration of Trust effective January 8, 2009 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #5 on Form N-1A | (a)(3) | 4/29/2009 |
(a)(4) | Amendment No. 4 to the Agreement and Declaration of Trust effective January 14, 2010 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #8 on Form N-1A | (a)(4) | 4/14/2010 |
(a)(5) | Amendment No. 5 to the Agreement and Declaration of Trust effective April 6, 2010 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #9 on Form N-1A | (a)(5) | 4/30/2010 |
(a)(6) | Amendment No. 6 to the Agreement and Declaration of Trust effective November 11, 2010 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #15 on Form N-1A | (a)(6) | 4/29/2011 |
(a)(7) | Amendment No. 7 to the Agreement and Declaration of Trust effective January 13, 2011 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #15 on Form N-1A | (a)(7) | 4/29/2011 |
(a)(8) | Amendment No. 8 to the Agreement and Declaration of Trust effective September 15, 2011 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #20 on Form N-1A | (a)(8) | 3/2/2012 |
(a)(9) | Amendment No. 9 to the Agreement and Declaration of Trust effective January 12, 2012 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #20 on Form N-1A | (a)(9) | 3/2/2012 |
(a)(10) | Amendment No. 10 to the Agreement and Declaration of Trust effective June 14, 2012 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #31 on Form N-1A | (a)(10) | 4/26/2013 |
(a)(11) | Amendment No. 11 to the Agreement and Declaration of Trust effective September 13, 2012 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #31 on Form N-1A | (a)(11) | 4/26/2013 |
(a)(12) | Amendment No. 12 to the Agreement and Declaration of Trust effective January 16, 2013 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #31 on Form N-1A | (a)(12) | 4/26/2013 |
(a)(13) | Amendment No. 13 to the Agreement and Declaration of Trust effective April 17, 2013 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #31 on Form N-1A | (a)(13) | 4/26/2013 |
(a)(14) | Amendment No. 14 to the Agreement and Declaration of Trust effective April 11, 2014 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #38 on Form N-1A | (a)(14) | 4/29/2014 |
(a)(15) | Amendment No. 15 to the Agreement and Declaration of Trust effective April 14, 2015 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #46 on Form N-1A | (a)(15) | 5/15/2015 |
(a)(16) | Amendment No. 16 to the Agreement and Declaration of Trust effective April 19, 2016 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (a)(16) | 4/28/2016 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(a)(17) | Amendment No. 17 to the Agreement and Declaration of Trust effective November 14, 2016 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #54 on Form N-1A | (a)(17) | 2/17/2017 |
(a)(18) | Amendment No. 18 to the Agreement and Declaration of Trust effective April 21, 2017 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #55 on Form N-1A | (a)(18) | 4/27/2017 |
(a)(19) | Amendment No. 19 to the Agreement and Declaration of Trust effective November 14, 2017 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #59 on Form N-1A | (a)(19) | 12/19/2017 |
(a)(20) | Amendment No. 20 to the Agreement and Declaration of Trust effective December 19, 2017 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #61 on Form N-1A | (a)(20) | 2/21/2018 |
(a)(21) | Amendment No. 21 to the Agreement and Declaration of Trust effective May 1, 2018 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (a)(21) | 12/7/2018 |
(a)(22) | Amendment No. 22 to the Agreement and Declaration of Trust effective September 13, 2018 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (a)(22) | 12/7/2018 |
(a)(23) | Amendment No. 23 to the Agreement and Declaration of Trust effective January 31, 2019 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #68 on Form N-1A | (a)(23) | 4/26/2019 |
(a)(24) | Amendment No. 24 to the Agreement and Declaration of Trust effective June 19, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (a)(24) | 4/28/2020 |
(b) | By-laws, effective September 6, 2007, most recently amended February 10, 2016 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (b) | 4/28/2016 |
(c) |
Stock Certificate:
Not Applicable. |
||||||
(d)(1) | Management Agreement (amended and restated), dated April 25, 2016, between Columbia Management Investment Advisers, LLC, Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (d)(1) | 4/28/2016 |
(d)(1)(i) | Schedule A and Schedule B, effective July 1, 2019, to the Management Agreement (amended and restated), dated April 25, 2016, between Columbia Management Investment Advisers, LLC, the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II | Incorporated by Reference | Columbia Funds Series Trust | 333-89661 | Post-Effective Amendment #184 on Form N-1A | (d)(1)(i) | 7/29/2019 |
(d)(2) | Management Agreement, dated November 15, 2017, between Columbia Management Investment Advisers, LLC, the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #59 on Form N-1A | (d)(2) | 12/19/2017 |
(d)(2)(i) | Schedule A and Schedule B, effective February 2, 2018, to the Management Agreement between Columbia Management Investment Advisers, LLC, the Registrant, Columbia Funds Series Trust and Columbia Funds Variable Series Trust II | Incorporated by Reference | Columbia Funds Series Trust II | 333-131683 | Post-Effective Amendment #175 on Form N-1A | (d)(2)(i) | 2/16/2018 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(d)(3) | Management Agreement, effective May 1, 2016, between Columbia Management Investment Advisers, LLC and CVPCSF Offshore Fund, Ltd., a wholly-owned subsidiary of Columbia Variable Portfolio - Commodity Strategy Fund, a series of Columbia Funds Variable Series Trust II | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (d)(3) | 4/28/2016 |
(d)(4) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and American Century Investment Management, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #39 on Form N-1A | (d)(4) | 5/15/2014 |
(d)(4)(i) | Amendment No. 1, as of September 20, 2017, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and American Century Investment Management, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #59 on Form N-1A | (d)(4)(i) | 12/19/2017 |
(d)(5) | Subadvisory Agreement, dated March 13, 2018, between Columbia Management Investment Advisers, LLC and AQR Capital Management, LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #62 on Form N-1A | (d)(5) | 4/27/2018 |
(d)(6)(i) | Amended and Restated Subadvisory Agreement, dated April 26, 2018, between Columbia Management Investment Advisers, LLC and BlackRock Financial Management, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #62 on Form N-1A | (d)(6)(i) | 4/27/2018 |
(d)(6)(ii) | Sub-Subadvisory Agreement, dated April 26, 2018, between BlackRock Financial Management, Inc. and BlackRock International Limited | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #62 on Form N-1A | (d)(6)(ii) | 4/27/2018 |
(d)(7) | Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and BMO Asset Management Corp. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #55 on Form N-1A | (d)(6) | 4/27/2017 |
(d)(7)(i) | Amendment No. 1, as of August 2, 2018, to the Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and BMO Asset Management Corp. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (d)(7)(i) | 12/7/2018 |
(d)(8) | Subadvisory Agreement, dated January 2, 2018, between Columbia Management Investment Advisers, LLC and CenterSquare Investment Management LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #61 on Form N-1A | (d)(7) | 2/21/2018 |
(d)(9) | Subadvisory Agreement, dated September 23, 2011, amended December 5, 2013 (Amendment No. 1), between Columbia Management Investment Advisers, LLC and Dimensional Fund Advisors LP | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #39 on Form N-1A | (d)(9) | 5/15/2014 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(d)(14)(i) | Amendment No. 1, as of February 10, 2016, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC and Massachusetts Financial Services Company | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (d)(20) | 4/28/2016 |
(d)(14)(ii) | Amendment No. 2, as of September 20, 2017, to the Subadvisory Agreement, dated April 8, 2010, as amended February 10, 2016, between Columbia Management Investment Advisers, LLC and Massachusetts Financial Services Company | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #59 on Form N-1A | (d)(17)(ii) | 12/19/2017 |
(d)(15) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Morgan Stanley Investment Management, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #39 on Form N-1A | (d)(20) | 5/15/2014 |
(d)(15)(i) | Amendment No. 1, as of February 10, 2016, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC and Morgan Stanley Investment Management, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (d)(22) | 4/28/2016 |
(d)(15)(ii) | Amendment No. 2, as of March 27, 2018, to the Subadvisory Agreement, dated April 8, 2010, as amended February 10, 2016, between Columbia Management Investment Advisers, LLC and Morgan Stanley Investment Management, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (d)(17)(ii) | 12/7/2018 |
(d)(16) | Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and Nuveen Asset Management, LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #55 on Form N-1A | (d)(26) | 4/27/2017 |
(d)(16)(i) | Amendment No. 1, dated May 31, 2018 to the Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and Nuveen Asset Management, LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (d)(18)(i) | 12/7/2018 |
(d)(17) | Subadvisory Agreement, dated April 18, 2019, between Columbia Management Investment Advisers, LLC and Scout Investments, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #70 on Form N-1A | (d)(18) | 5/20/2019 |
(d)(18) | Subadvisory Agreement, dated June 18, 2014, between Columbia Management Investment Advisers, LLC and Segall Bryant & Hamill, LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #41 on Form N-1A | (d)(27) | 8/20/2014 |
(d)(18)(i) | Amendment No. 1, dated March 13, 2018, to the Subadvisory Agreement, dated June 18, 2014, between Columbia Management Investment Advisers, LLC and Segall Bryant & Hamill, LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (d)(21)(i) | 12/7/2018 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(d)(23) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #39 on Form N-1A | (d)(30) | 5/15/2014 |
(d)(23)(i) | Amendment No. 1, as of July 18, 2014, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #42 on Form N-1A | (d)(34) | 10/15/2014 |
(d)(23)(ii) | Amendment No. 2, dated April 21, 2017, to the Subadvisory Agreement, dated April 8, 2010, as amended July 18, 2014, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #57 on Form N-1A | (d)(35) | 9/18/2017 |
(d)(23)(iii) | Amendment No. 3, as of June 25, 2018, to the Subadvisory Agreement, dated April 8, 2010, as amended July 18, 2014 and April 21, 2017, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #66 on Form N-1A | (d)(26)(iii) | 12/7/2018 |
(d)(24) | Subadvisory Agreement, dated June 21, 2017, between Columbia Management Investment Advisers, LLC and Westfield Capital Management Company, L.P. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #57 on Form N-1A | (d)(36) | 9/18/2017 |
(d)(25) | Subadvisory Agreement, dated March 19, 2019, between Columbia Management Investment Advisers, LLC and William Blair Investment Management, LLC | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #70 on Form N-1A | (d)(26) | 5/20/2019 |
(e)(1) | Amended and Restated Distribution Agreement by and between Registrant and Columbia Management Investment Distributors, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #50 on Form N-1A | (e)(1) | 4/28/2016 |
(e)(1)(i) | Schedule I, effective July 1, 2019, and Schedule II, dated September 7, 2010, to the Distribution Agreement, amended and restated as of March 1, 2016, between Registrant and Columbia Management Investment Distributors, Inc. | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (e)(1)(i) | 4/28/2020 |
(f) | Deferred Compensation Plan, adopted as of December 31, 2011 | Incorporated by Reference | Columbia Funds Series Trust II | 333-131683 | Post-Effective Amendment #52 on Form N-1A | (f) | 2/24/2012 |
(g)(1) | Second Amended and Restated Master Global Custody Agreement with JPMorgan Chase Bank, N.A., dated March 7, 2011 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #39 on Form N-1A | (g)(1) | 5/15/2014 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(h)(2)(i) | Schedule A, effective July 1, 2019, to the Amended and Restated Fee Waiver and Expense Cap Agreement, effective July 1, 2016, by and among Columbia Management Investment Advisers, LLC, Columbia Management Investment Distributors, Inc., Columbia Management Investment Services Corp., the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II | Incorporated by Reference | Columbia Funds Series Trust | 333-89661 | Post-Effective Amendment #184 on Form N-1A | (h)(2)(i) | 7/29/2019 |
(h)(3) | Agreement and Plan of Reorganization, dated September 11, 2007, between RiverSource Variable Portfolio Funds, each a series of a Minnesota corporation, and corresponding RiverSource Variable Portfolio Funds, each a series of RiverSource Variable Series Trust, now known as Columbia Funds Variable Series Trust II, a Massachusetts business trust, and between RiverSource Variable Portfolio – Core Bond Fund, a series of RiverSource Variable Series Trust, and RiverSource Variable Portfolio – Diversified Bond Fund, a series of RiverSource Variable Series Trust, now known as Columbia Funds Variable Series Trust II | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #2 on Form N-1A | (h)(5) | 4/21/2008 |
(h)(4) | Agreement and Plan of Reorganization, dated December 20, 2010 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #15 on Form N-1A | (h)(9) | 4/29/2011 |
(h)(5) | Agreement and Plan of Redomiciling, dated December 20, 2010 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #15 on Form N-1A | (h)(10) | 4/29/2011 |
(h)(6) | Agreement and Plan of Reorganization, dated Octob8er 9, 2012 | Incorporated by Reference | Columbia Funds Series Trust | 333-89661 | Post-Effective Amendment #117 on Form N-1A | (h)(9) | 5/30/2013 |
(h)(7) | Agreement and Plan of Reorganization, dated December 17, 2015 | Incorporated by Reference | Columbia Funds Series Trust | 333-208706 | Registration Statement on Form N-14 | (4) | 12/22/2015 |
(h)(8) | Amended and Restated Credit Agreement, as of December 3, 2019 | Incorporated by Reference | Columbia Funds Series Trust II | 333-131683 | Registration Statement on Form N-1A | (h)(7) | 12/20/2019 |
(h)(9) | Master Inter-Fund Lending Agreement, dated May 1, 2018 | Incorporated by Reference | Columbia Funds Series Trust II | 333-131683 | Registration Statement on Form N-1A | (h)(11) | 5/25/2018 |
(h)(9)(i) | Schedule A and Schedule B to the Master Inter-Fund Lending Agreement, dated July 1, 2019 | Incorporated by Reference | Columbia Funds Series Trust | 333-208706 | Registration Statement on Form N-1A | (h)(8)(i) | 7/29/2019 |
(i)(1) | Opinion and consent of counsel as to the legality of the securities being registered | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #38 on Form N-1A | (i) | 4/29/2014 |
(i)(2) | Opinion and consent of counsel as to the legality of the securities being registered for Columbia Variable Portfolio – Select Large Cap Equity Fund | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #59 on Form N-1A | (i)(2) | 12/19/2017 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(j) | Consent of Independent Registered Public Accounting Firm | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (j) | 4/28/2020 |
(k) | Omitted Financial Statements: Not Applicable. | ||||||
(l) | Initial Capital Agreement: Not Applicable. | ||||||
(m)(1) | Plan of Distribution and Agreement of Distribution, effective May 1, 2009, amended and restated March 7, 2011, between the Registrant and Columbia Management Investment Distributors, Inc. | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #38 on Form N-1A | (m)(1) | 4/29/2014 |
(m)(1)(i) | Schedule A, effective July 1, 2019, to the Plan of Distribution and Agreement of Distribution, effective May 1, 2009, amended and restated March 7, 2011, between the Registrant and Columbia Management Investment Distributors, Inc. | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (m)(1)(i) | 4/28/2020 |
(n) | Rule 18f – 3(d) Plan, amended and restated June 19, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (n) | 4/28/2020 |
(o) | Reserved. | ||||||
(p)(1) | Code of Ethics adopted under Rule 17j-1 for Registrant, effective March 2019 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #68 on Form N-1A | (p)(1) | 4/26/2019 |
(p)(2) | Columbia Threadneedle Global Personal Account Dealing and Code of Ethics Policy, effective December 2019 | Incorporated by Reference | Columbia Funds Series Trust II | 333-131683 | Post-Effective Amendment #209 on Form N-1A | (p)(2) | 2/27/2019 |
(p)(3) | American Century Investment Management, Inc. Code of Ethics, updated August 21, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(3) | 4/28/2020 |
(p)(4) | AQR Capital Management, LLC Code of Ethics, as amended April 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #349 on Form N-1A | (p)(3) | 4/25/2019 |
(p)(5) | BlackRock Financial Management, Inc. Code of Ethics, effective November 23, 2018 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #68 on Form N-1A | (p)(5) | 4/26/2019 |
(p)(6) | BMO Asset Management Corp. Code of Ethics, dated October 30, 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #374 on Form N-1A | (p)(9) | 4/27/2020 |
(p)(7) | CenterSquare Investment Management LLC Code of Ethics, effective December 5, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(7) | 4/28/2020 |
(p)(8) | Dimensional Fund Advisors LP Code of Ethics, effective January, 2020 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(8) | 4/28/2020 |
(p)(9) | J.P. Morgan Investment Management Inc. Code of Ethics, effective February 1, 2005, last revised December 13, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(9) | 4/28/2020 |
(p)(10) | Jacobs Levy Equity Management, Inc. Code of Ethics, dated January 1, 2016 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #62 on Form N-1A | (p)(12) | 4/27/2017 |
Exhibit
Number |
Exhibit Description |
Filed Herewith or
Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant
that Made the Filing |
File No.
of Such Registrant |
Type of
Filing |
Exhibit of
Document in that Filing |
Filing
Date |
|||
(p)(11) | Loomis, Sayles & Company, L.P. Code of Ethics, effective January 14, 2000, as amended April 18, 2018 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #332 on Form N-1A | (p)(11) | 8/27/2018 |
(p)(12) | Los Angeles Capital Management and Equity Research, Inc. Code of Ethics, dated January 7, 2020 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(12) | 4/28/2020 |
(p)(13) | Massachusetts Financial Services Company Code of Ethics, effective December 16, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(13) | 4/28/2020 |
(p)(14) | Morgan Stanley Investment Management Inc. Code of Ethics, effective December 12, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(14) | 4/28/2020 |
(p)(15) | Nuveen Asset Management, LLC Code of Ethics, dated August 26, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(15) | 4/28/2020 |
(p)(16) | Scout Investments, Inc. Code of Ethics, effective August 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(16) | 4/28/2020 |
(p)(17) | Segall Bryant & Hamill, LLC Code of Ethics, dated October 1, 2018 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #68 on Form N-1A | (p)(18) | 4/26/2019 |
(p)(18) | T. Rowe Price Group, Inc. and Its Affiliates Code of Ethics, as of December 1, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(18) | 4/28/2020 |
(p)(19) | TCW Investment Management Company LLC Code of Ethics, dated December 16, 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #374 on Form N-1A | (p)(5) | 4/27/2020 |
(p)(20) | Victory Capital Management Inc. Code of Ethics, effective July 1, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(20) | 4/28/2020 |
(p)(21) | Wells Capital Management Incorporated Code of Ethics, effective January 2020 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #374 on Form N-1A | (p)(11) | 4/27/2020 |
(p)(22) | Westfield Capital Management Company, L.P. Code of Ethics, as of August 16, 2019 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (p)(22) | 4/28/2020 |
(p)(23) | William Blair Investment Management, LLC Code of Ethics, as of July 31, 2018 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #70 on Form N-1A | (p)(24) | 5/20/2019 |
(q)(1) | Trustees’ Power of Attorney to sign Amendments to this Registration Statement, dated January 1, 2018 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #61 on Form N-1A | (q)(1) | 2/21/2018 |
(q)(2) | Power of Attorney for Michael G. Clarke, dated May 23, 2016 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #52 on Form N-1A | (q)(3) | 6/1/2016 |
(q)(3) | Power of Attorney for Christopher O. Petersen, dated February 16, 2015 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #44 on Form N-1A | (q)(5) | 2/20/2015 |
(q)(4) | Power of Attorney for Joseph Beranek, dated January 3, 2020 | Filed herewith | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #71 on Form N-1A | (q)(4) | 4/28/2020 |
(1) | Columbia Management, a wholly owned subsidiary of Ameriprise Financial, Inc., performs investment advisory services for the Registrant and certain other clients. Information regarding the business of Columbia Management and the directors and principal officers of Columbia Management is also included in the Form ADV filed by Columbia Management with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-25943), which information is incorporated herein by reference. In addition to their position with Columbia Management, certain directors and officers of Columbia Management also hold various positions with, and engage in business for, Ameriprise Financial, Inc. or its other subsidiaries. |
(2) | American Century Investment Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of American Century Investment Management, Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by American Century Investment Management, Inc. and is incorporated herein by reference. Information about the business of American Century Investment Management, Inc. and the directors and principal executive officers of American Century Investment Management, Inc. is also included in the Form ADV filed by American Century Investment Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-8174), which information is incorporated herein by reference. |
(3) | AQR Capital Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of AQR Capital Management, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s portfolio(s) subadvised by AQR Capital Management, LLC and is incorporated herein by reference. Information about the business of AQR Capital Management, LLC and the directors and principal executive officers of AQR Capital Management, LLC is also included in the Form ADV filed by AQR Capital Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-55543), which information is incorporated herein by reference. |
(4) | BlackRock Financial Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of BlackRock Financial Management, Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by BlackRock Financial Management, Inc. and is incorporated herein by reference. Information about the business of BlackRock Financial Management, Inc. and the directors and principal executive officers of BlackRock Financial Management, Inc. is also included in the Form ADV filed by BlackRock Financial Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-48433), which information is incorporated herein by reference. |
(5) | BlackRock International Limited performs investment management services for the Registrant and certain other clients. Information regarding the business of BlackRock International Limited is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by BlackRock International Limited and is incorporated herein by reference. Information about the business of BlackRock International Limited and the directors and principal executive officers of BlackRock International Limited is also included in the Form ADV filed by BlackRock International Limited with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-51087), which information is incorporated herein by reference. |
(6) | BMO Asset Management Corp. performs investment management services for the Registrant and certain other clients. Information regarding the business of BMO Asset Management Corp. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s portfolio(s) subadvised by BMO Asset Management Corp. and is incorporated herein by reference. Information about the business of BMO Asset Management Corp. and the directors and principal executive officers of BMO Asset Management Corp. is also included in the Form ADV filed by BMO Asset Management Corp. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-35533), which information is incorporated herein by reference. |
(7) | CenterSquare Investment Management LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of CenterSquare Investment Management LLC is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by CenterSquare Investment Management LLC and is incorporated herein by reference. Information about the business of CenterSquare |
Investment Management LLC and the directors and principal executive officers of CenterSquare Investment Management LLC is also included in the Form ADV filed by CenterSquare Investment Management LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-111965), which information is incorporated herein by reference. |
(8) | Dimensional Fund Advisors LP performs investment management services for the Registrant and certain other clients. Information regarding the business of Dimensional Fund Advisors, L.P. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Dimensional Fund Advisors, L.P. and is incorporated herein by reference. Information about the business of Dimensional Fund Advisors, L.P. and the directors and principal executive officers of Dimensional Fund Advisors, L.P. is also included in the Form ADV filed by Dimensional Fund Advisors, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-16283), which information is incorporated herein by reference. |
(9) | J.P. Morgan Investment Management Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of J.P. Morgan Investment Management Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by J.P. Morgan Investment Management Inc. and is incorporated herein by reference. Information about the business of J.P. Morgan Investment Management Inc. and the directors and principal executive officers of J.P. Morgan Investment Management Inc. is also included in the Form ADV filed by J.P. Morgan Investment Management Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-21011), which information is incorporated herein by reference. |
(10) | Jacobs Levy Equity Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Jacobs Levy Equity Management, Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Jacobs Levy Equity Management, Inc. and is incorporated herein by reference. Information about the business of Jacobs Levy Equity Management, Inc. and the directors and principal executive officers of Jacobs Levy Equity Management, Inc. is also included in the Form ADV filed by Jacobs Levy Equity Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-28257), which information is incorporated herein by reference. |
(11) | Loomis, Sayles & Company, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Loomis, Sayles & Company, L.P. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Loomis, Sayles & Company, L.P. and is incorporated herein by reference. Information about the business of Loomis, Sayles & Company, L.P. and the directors and principal executive officers of Loomis, Sayles & Company, L.P.is also included in the Form ADV filed by Loomis, Sayles & Company, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-170), which information is incorporated herein by reference. |
(12) | Los Angeles Capital Management and Equity Research, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Los Angeles Capital Management and Equity Research, Inc. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s portfolio(s) subadvised by Los Angeles Capital Management and Equity Research, Inc. and is incorporated herein by reference. Information about the business of Los Angeles Capital Management and Equity Research, Inc. and the directors and principal executive officers of Los Angeles Capital Management and Equity Research, Inc. is also included in the Form ADV filed by Los Angeles Capital Management and Equity Research, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60934), which information is incorporated herein by reference. |
(13) | Massachusetts Financial Services Company performs investment management services for the Registrant and certain other clients. Information regarding the business of Massachusetts Financial Services Company is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Massachusetts Financial Services Company and is incorporated herein by reference. Information about the business of Massachusetts Financial Services Company and the directors and principal executive officers of Massachusetts Financial Services Company is also included in the Form ADV filed by Massachusetts Financial Services Company with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-17352), which information is incorporated herein by reference. |
(14) | Morgan Stanley Investment Management Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Morgan Stanley Investment Management Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Morgan Stanley Investment Management Inc. and is incorporated herein by reference. Information about the business of Morgan Stanley Investment Management Inc. and the directors and principal executive officers of Morgan Stanley |
Investment Management Inc. is also included in the Form ADV filed by Morgan Stanley Investment Management Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-15757), which information is incorporated herein by reference. |
(15) | Nuveen Asset Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Nuveen Asset Management, LLC is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Nuveen Asset Management, LLC and is incorporated herein by reference. Information about the business of Nuveen Asset Management, LLC and the directors and principal executive officers of Nuveen Asset Management, LLC is also included in the Form ADV filed by Nuveen Asset Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-71957), which information is incorporated herein by reference. |
(16) | Scout Investments, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Scout Investments, Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Scout Investments, Inc. and is incorporated herein by reference. Information about the business of Scout Investments, Inc. and the directors and principal executive officers of Scout Investments, Inc. is also included in the Form ADV filed by Scout Investments, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60188), which information is incorporated herein by reference. |
(17) | Segall Bryant & Hamill, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Segall Bryant & Hamill, LLC is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Segall Bryant & Hamill, LLC and is incorporated herein by reference. Information about the business of Segall Bryant & Hamill, LLC and the directors and principal executive officers of Segall Bryant & Hamill, LLC is also included in the Form ADV filed by Segall Bryant & Hamill, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-47232), which information is incorporated herein by reference. |
(18) | T. Rowe Price Associates, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of T. Rowe Price Associates, Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by T. Rowe Price Associates, Inc. and is incorporated herein by reference. Information about the business of T. Rowe Price Associates, Inc. and the directors and principal executive officers of T. Rowe Price Associates, Inc. is also included in the Form ADV filed by T. Rowe Price Associates, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-856), which information is incorporated herein by reference. |
(19) | TCW Investment Management Company LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of TCW Investment Management Company LLC is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by TCW Investment Management Company LLC and is incorporated herein by reference. Information about the business of TCW Investment Management Company LLC and the directors and principal executive officers of TCW Investment Management Company LLC is also included in the Form ADV filed by TCW Investment Management Company LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-29075), which information is incorporated herein by reference. |
(20) | Threadneedle International Limited performs investment management services for the Registrant and certain other clients. Information regarding the business of Threadneedle International Limited is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Threadneedle International Limited and is incorporated herein by reference. Information about the business of Threadneedle International Limited and the directors and principal executive officers of Threadneedle International Limited is also included in the Form ADV filed by Threadneedle International Limited with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-63196), which information is incorporated herein by reference. |
(21) | Victory Capital Management Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Victory Capital Management Inc. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Victory Capital Management Inc. and is incorporated herein by reference. Information about the business of Victory Capital Management Inc. and the directors and principal executive officers of Victory Capital Management Inc. is also included in the Form ADV filed by Victory Capital Management Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-46878), which information is incorporated herein by reference. |
(22) | Wells Capital Management Incorporated performs investment management services for the Registrant and certain other clients. Information regarding the business of Wells Capital Management Incorporated is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Wells Capital Management Incorporated and is incorporated herein by reference. Information about the business of Wells Capital Management Incorporated and the directors and principal executive officers of Wells Capital Management Incorporated is also included in the Form ADV filed by Wells Capital Management Incorporated with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-21122), which information is incorporated herein by reference. |
(23) | Westfield Capital Management Company, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Westfield Capital Management Company, L.P. is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by Westfield Capital Management Company, L.P. and is incorporated herein by reference. Information about the business of Westfield Capital Management Company, L.P. and the directors and principal executive officers of Westfield Capital Management Company, L.P. is also included in the Form ADV filed by Westfield Capital Management Company, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-69413), which information is incorporated herein by reference. |
(24) | William Blair Investment Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of William Blair Investment Management, LLC is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series that are subadvised by William Blair Investment Management, LLC and is incorporated herein by reference. Information about the business of William Blair Investment Management, LLC and the directors and principal executive officers of William Blair Investment Management, LLC is also included in the Form ADV filed by William Blair Investment Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-80640), which information is incorporated herein by reference. |
(a) | Columbia Management Investment Distributors, Inc. acts as principal underwriter for the following investment companies, including the Registrant: |
Columbia Acorn Trust; Columbia Funds Series Trust; Columbia Funds Series Trust I; Columbia Funds Series Trust II; Columbia Funds Variable Series Trust II; Columbia Funds Variable Insurance Trust and Wanger Advisors Trust. | |
(b) | As to each director, principal officer or partner of Columbia Management Investment Distributors, Inc. |
Name and
Principal Business Address* |
Position and Offices
with Principal Underwriter |
Positions and Offices with Registrant | ||
William F. Truscott | Chief Executive Officer and Director | Board Member, Senior Vice President | ||
Scott E. Couto | President and Director | None | ||
Michael S. Mattox | Chief Financial Officer | None | ||
Michael E. DeFao | Vice President, Chief Legal Officer and Assistant Secretary | Vice President and Assistant Secretary | ||
Stephen O. Buff | Vice President, Chief Compliance Officer | None | ||
James Bumpus | Vice President – National Sales Manager | None | ||
Thomas A. Jones | Vice President and Head of Strategic Relations | None | ||
Gary Rawdon | Vice President – Sales Governance and Administration | None | ||
Leslie A. Walstrom | Vice President and Head of North America Marketing | None | ||
Daniel J. Beckman | Vice President and Head of North America Product and Director | None | ||
Marc Zeitoun | Chief Operating Officer, North American Distribution | None | ||
Thomas R. Moore | Secretary | None | ||
Paul B. Goucher | Vice President and Assistant Secretary | Senior Vice President and Assistant Secretary | ||
Amy L. Hackbarth | Vice President and Assistant Secretary | None | ||
Mark D. Kaplan | Vice President and Assistant Secretary | None | ||
Nancy W. LeDonne | Vice President and Assistant Secretary | None | ||
Ryan C. Larrenaga | Vice President and Assistant Secretary | Senior Vice President, Chief Legal Officer and Secretary | ||
Joseph L. D’Alessandro | Vice President and Assistant Secretary | Assistant Secretary |
Name and
Principal Business Address* |
Position and Offices
with Principal Underwriter |
Positions and Offices with Registrant | ||
Christopher O. Petersen | Vice President and Assistant Secretary |
President and
Principal Executive Officer |
||
Shweta J. Jhanji | Vice President and Treasurer | None | ||
Michael Tempesta | Anti-Money Laundering Officer and Identity Theft Prevention Officer | None | ||
Kevin Wasp | Ombudsman | None | ||
Kristin Weisser | Conflicts Officer | None |
* | The principal business address of Columbia Management Investment Distributors, Inc. is 225 Franklin Street, Boston, MA 02110. |
(c) | Not Applicable. |
■ | Registrant, 225 Franklin Street, Boston, MA 02110; |
■ | Registrant’s investment adviser and administrator, Columbia Management Investment Advisers, LLC, 225 Franklin Street, Boston, MA 02110; |
■ | Registrant’s subadviser, American Century Investment Management, Inc., 4500 Main Street, Kansas City, MO 64111-7709; |
■ | Registrant’s subadviser, AQR Capital Management, LLC, Two Greenwich Plaza, 3rd Floor, Greenwich, CT 06830; |
■ | Registrant’s subadviser, BlackRock Financial Management, Inc., 55 East 52nd Street, New York, NY 10055; |
■ | Registrant’s sub-subadviser, BlackRock International Limited, Exchange Place One, 1 Semple Street, Edinburgh, EH3 8BL, Scotland; |
■ | Registrant’s subadviser, BMO Asset Management Corp., 115 South LaSalle Street, 11th Floor, Chicago, IL, 60603; |
■ | Registrant’s subadviser, CenterSquare Investment Management LLC, 630 W Germantown Pike, Suite 300, Plymouth Meeting, PA 19462; |
■ | Registrant’s subadviser, Dimensional Fund Advisors LP, 6300 Bee Cave Road, Building One, Austin, TX 78746; |
■ | Registrant’s subadviser, J.P. Morgan Investment Management Inc., 383 Madison Avenue, New York, NY 10179; |
■ | Registrant’s subadviser, Jacobs Levy Equity Management, Inc., 100 Campus Drive, 2nd Floor West, Florham Park, NJ 07932-0650; |
■ | Registrant’s subadviser, Loomis, Sayles & Company, L.P., One Financial Center, Boston, MA 02111-2621; |
■ | Registrant’s subadviser, Los Angeles Capital Management and Equity Research, Inc., 11150 Santa Monica Blvd., Suite 200, Los Angeles, CA 90025; |
■ | Registrant’s subadviser, Massachusetts Financial Services Company, 111 Huntington Ave., Boston, MA 02199; |
■ | Registrant’s subadviser, Morgan Stanley Investment Management Inc., 522 Fifth Avenue, New York, NY 10036; |
■ | Registrant’s subadviser, Nuveen Asset Management, LLC, 333 West Wacker Drive, Chicago, IL 60606; |
■ | Registrant’s subadviser, Scout Investments, Inc., 1201 Walnut Street, 21st Floor, Kansas City, MO 64106; |
■ | Registrant’s subadviser, Segall Bryant & Hamill, LLC, 540 West Madison Street, Suite 1900, Chicago, IL 60661-2551; |
■ | Registrant’s subadviser, T. Rowe Price Associates, Inc., 100 East Pratt Street, Baltimore, MD 21202; |
■ | Registrant’s subadviser, TCW Investment Management Company LLC, 865 South Figueroa Street, Suite 1800, Los Angeles, CA 90017; |
■ | Registrant’s subadviser, Threadneedle International Limited, Cannon Place, 78 Cannon Street, London EC4N 6AG, UK; |
■ | Registrant’s subadviser, Victory Capital Management Inc., 15935 La Cantera Parkway, San Antonio, TX 78256; |
■ | Registrant’s subadviser, Wells Capital Management Incorporated, 525 Market Street, San Francisco, CA 94105; |
■ | Registrant’s subadviser, Westfield Capital Management Company, L.P., One Financial Center, Boston, MA 02111; |
■ | Registrant’s subadviser, William Blair Investment Management, LLC, 150 North Riverside Plaza, Chicago, IL, 60606; |
■ | Former subadviser, Columbia Wanger Asset Management, LLC, 71 S. Wacker Drive, Chicago, IL 60606; |
■ | Former subadviser, Barrow, Hanley, Mewhinney & Strauss, LLC, 2200 Ross Avenue, 31st Floor, Dallas, TX 75201-2761; |
■ | Former subadviser, Davis Selected Advisers, L.P., 2949 East Elvira Road, Suite 101, Tucson, AZ 85756; |
■ | Former subadviser, Denver Investment Advisors LLC, 370 17th Street, Suite 5000, Denver, CO 80202 (merged into Segall Bryant & Hamill, LLC, 540 West Madison Street, Suite 1900, Chicago, IL 60661-2551); |
■ | Former subadviser, Eaton Vance Management, Two International Place, Boston, MA 02110; |
■ | Former subadviser, FIAM LLC (d/b/a Pyramis Global Advisors), 900 Salem Street, Smithfield, RI 02917; |
■ | Former subadviser, Donald Smith & Co., Inc., 152 West 57th Street, 22nd Floor, New York, NY 10019; |
■ | Former subadviser, Goldman Sachs Asset Management, L.P., 200 West Street, New York, NY 10282; |
■ | Former subadviser, Holland Capital Management LLC, 303 W. Madison Street, Suite 700, Chicago, IL 60606; |
■ | Former subadviser, Invesco Advisers, Inc., 1555 Peachtree Street, N.E., Atlanta, GA 30309; |
■ | Former subadviser, Jennison Associates LLC, 466 Lexington Avenue, New York, NY 10017; |
■ | Former subadviser, Kennedy Capital Management, Inc., 10829 Olive Boulevard, St. Louis, MO 63141; |
■ | Former subadviser, The London Company of Virginia, 1800 Bayberry Court, Suite 301, Richmond, VA 23226; |
■ | Former subadviser, Marsico Capital Management, LLC, 1200 17th Street, Suite 1600, Denver, CO 80202; |
■ | Former subadviser, Mondrian Investment Partners Limited, 10 Gresham Street, 5th Floor, London EC2V7JD, UK; |
■ | Former subadviser, NFJ Investment Group LLC, 2100 Ross Avenue, Suite 700, Dallas, TX 75201 (merged into Allianz Global Investors U.S. LLC, 2100 Ross Avenue, Suite 700, Dallas, TX 75201); |
■ | Former subadviser, OppenheimerFunds, Inc. 225 Liberty Street, New York, NY 10281; |
■ | Former subadviser, Pacific Investment Management Company LLC, 650 Newport Center Drive, Newport Beach, CA 92660; |
■ | Former subadviser, Palisade Capital Management, L.L.C., One Bridge Plaza North, Suite 695, Fort Lee, NJ 07024; |
■ | Former subadviser, River Road Asset Management, LLC, 462 South Fourth Street, Suite 2000, Louisville, KY 40202-3466; |
■ | Former subadviser, Sit Investment Associates, Inc., 3300 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402; |
■ | Former subadviser, Snow Capital Management L.P., 1605 Carmody Court, Suite 300, Sewickley, PA 15143-8992; |
■ | Former subadviser, Turner Investments, L.P., 1205 Westlakes Drive, Suite 100, Berwyn, PA 19312 (merged into Turner Investments LLC, 1000 Chesterbrook Boulevard, 1st Floor, Berwyn, PA 19312-2414); |
■ | Former subadviser, Winslow Capital Management, LLC, 4400 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402; |
■ | Registrant’s principal underwriter, Columbia Management Investment Distributors, Inc., 225 Franklin Street, Boston, MA 02110; |
■ | Registrant’s transfer agent, Columbia Management Investment Services Corp., 225 Franklin Street, Boston, MA 02110; |
■ | Registrant’s sub-transfer agent, DST Asset Manager Services, 2000 Crown Colony Dr., Quincy, MA 02169; and |
■ | Registrant’s custodian, JPMorgan Chase Bank, N.A., 1 Chase Manhattan Plaza, New York, NY 10005. |
COLUMBIA FUNDS VARIABLE SERIES TRUST II | |
By: | /s/ Christopher O. Petersen |
Christopher O. Petersen
President |
Signature | Capacity | Signature | Capacity |
/s/ Christopher O. Petersen |
President
(Principal Executive Officer) |
/s/ Patricia M. Flynn* | Trustee |
Christopher O. Petersen | Patricia M. Flynn | ||
/s/ Michael G. Clarke* |
Chief Financial Officer,
Principal Financial Officer and Senior Vice President |
/s/ Brian J. Gallagher* | Trustee |
Michael G. Clarke | Brian J. Gallagher | ||
/s/ Joseph Beranek* |
Treasurer, Chief
Accounting Officer (Principal Accounting Officer) and Principal Financial Officer |
/s/ Anthony M. Santomero* | Trustee |
Joseph Beranek | Anthony M. Santomero | ||
/s/ Catherine James Paglia* | Chair of the Board | /s/ Minor M. Shaw* | Trustee |
Catherine James Paglia | Minor M. Shaw | ||
/s/ George S. Batejan* | Trustee | /s/ William F. Truscott* | Trustee |
George S. Batejan | William F. Truscott | ||
/s/ Kathleen A. Blatz* | Trustee | /s/ Sandra Yeager* | Trustee |
Kathleen A. Blatz | Sandra Yeager | ||
/s/ Pamela G. Carlton* | Trustee | ||
Pamela G. Carlton |
* |
By:
Name: |
/s/ Joseph D’Alessandro | |
Joseph D’Alessandro**
Attorney-in-fact |
|||
** | Executed by Joseph D’Alessandro on behalf of Michael G. Clarke pursuant to a Power of Attorney, dated May 23, 2016 and incorporated by reference to Post-Effective Amendment No. 52 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (q)(3)), filed with the Commission on June 1, 2016, on behalf of Joseph Beranek pursuant to a Power of Attorney, dated January 3, 2020, filed herewith as Exhibit (q)(4) to Post-Effective Amendment No.71 to Registration Statement No. 333-146374 of the Registrant on Form N-1A and on behalf of each of the Trustees pursuant to a Trustees Power of Attorney, dated January 1, 2018 and incorporated by reference to Post-Effective Amendment No. 61 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (q)(1)), filed with the Commission on February 21, 2018. |
(a)(24) | Amendment No. 24 to the Agreement and Declaration of Trust effective June 19, 2019 |
(d)(12)(ii) | Amendment No. 2, as of October 21, 2019, to the Subadvisory Agreement, dated January 15, 2014, as amended November 19, 2015, between Columbia Management Investment Advisers, LLC and Loomis, Sayles & Company, L.P. |
(d)(12)(iii) | Amendment No. 3, as of February 5, 2020, to the Subadvisory Agreement, dated January 15, 2014, as amended October 21, 2019 and November 19, 2015, between Columbia Management Investment Advisers, LLC and Loomis, Sayles & Company, L.P. |
(d)(13)(ii) | Amendment No. 2, as of November 20, 2019, to the Subadvisory Agreement, dated February 15, 2017, as amended May 31, 2018, between Columbia Management Investment Advisers, LLC and Los Angeles Capital Management and Equity Research, Inc. |
(d)(20)(i) | Amendment No. 1, as of November 1, 2019, to the Subadvisory Agreement, dated January 15, 2014, between Columbia Management Investment Advisers, LLC and TCW Investment Management Company |
(d)(22)(i) | Amendment No. 1, as of May 13, 2019, to Subadvisory Agreement, dated June 19, 2013, between Columbia Management Investment Advisers, LLC and Victory Capital Management Inc. |
(e)(1)(i) | Schedule I, effective July 1, 2019, and Schedule II, dated September 7, 2010, to the Distribution Agreement, amended and restated as of March 1, 2016, between Registrant and Columbia Management Investment Distributors, Inc. |
(j) | Consent of Independent Registered Public Accounting Firm |
(m)(1)(i) | Schedule A, effective July 1, 2019, to the Plan of Distribution and Agreement of Distribution, effective May 1, 2009, amended and restated March 7, 2011, between the Registrant and Columbia Management Investment Distributors, Inc. |
(n) | Rule 18f – 3(d) Plan, amended and restated June 19, 2019 |
(p)(3) | American Century Investment Management, Inc. Code of Ethics, updated August 21, 2019 |
(p)(7) | CenterSquare Investment Management LLC Code of Ethics, effective December 5, 2019 |
(p)(8) | Dimensional Fund Advisors LP Code of Ethics, effective January, 2020 |
(p)(9) | J.P. Morgan Investment Management Inc. Code of Ethics, effective February 1, 2005, last revised December 13, 2019 |
(p)(12) | Los Angeles Capital Management and Equity Research, Inc. Code of Ethics, dated January 7, 2020 |
(p)(13) | Massachusetts Financial Services Company Code of Ethics, effective December 16, 2019 |
(p)(14) | Morgan Stanley Investment Management Inc. Code of Ethics, effective December 12, 2019 |
(p)(15) | Nuveen Asset Management, LLC Code of Ethics, dated August 26, 2019 |
(p)(16) | Scout Investments, Inc. Code of Ethics, effective August 2019 |
(p)(17) | T. Rowe Price Group, Inc. and Its Affiliates Code of Ethics, as of December 1, 2019 |
(p)(20) | Victory Capital Management Inc. Code of Ethics, effective July 1, 2019 |
(p)(22) | Westfield Capital Management Company, L.P. Code of Ethics, as of August 16, 2019 |
(q)(4) | Power of Attorney for Joseph Beranek, dated January 3, 2020 |
COLUMBIA FUNDS VARIABLE SERIES TRUST II
AMENDMENT NO. 24 TO THE
AGREEMENT AND DECLARATION OF TRUST
WHEREAS, Section 5 of Article III of the Agreement and Declaration of Trust (the "Declaration of Trust") of Columbia Funds Variable Series Trust II (the "Trust"), dated September 11, 2007, as amended from time to time, a copy of which is on file in the Office of the Secretary of The Commonwealth of Massachusetts, authorizes the Trustees of the Trust to amend the Declaration of Trust to establish, to change or abolish and rescind the designation of any Series or class of Shares without authorization by vote of the Shareholders of the Trust; and
NOW, THEREFORE, The undersigned, being at least a majority of the Trustees of Columbia Funds Variable Series Trust II, do hereby certify that we have authorized the renaming of Columbia Variable Portfolio Mid Cap Value Fund to Columbia Variable Portfolio Select Mid Cap Value Fund, Columbia Variable Portfolio Select Large-Cap Value Fund to Columbia Variable Portfolio Select Large Cap Value Fund, Columbia Variable Portfolio Select Smaller-Cap Value Fund to Columbia Variable Portfolio Select Small Cap Value Fund, CTIVP MFS® Blended Research® Core Equity Fund to CTIVP Partners Core Equity Fund and CTIVP Oppenheimer International Growth Fund to CTIVP William Blair International Leaders Fund and have authorized the following amendment to said Declaration of Trust:
1.Section 6 of Article III is hereby amended by replacing the text preceding paragraph (a) with the following:
Without limiting the authority of the Trustees as set forth in Section 5, inter alia, to establish and designate any further Series or classes or to modify the rights and preferences of any Series or class, the following Series shall be, and are hereby, established and designated;
Columbia Variable Portfolio Balanced Fund
Columbia Variable Portfolio Commodity Strategy Fund
Columbia Variable Portfolio Core Equity Fund
Columbia Variable Portfolio Disciplined Core Fund
Columbia Variable Portfolio Dividend Opportunity Fund
Columbia Variable Portfolio Emerging Markets Bond Fund
Columbia Variable Portfolio Emerging Markets Fund
Columbia Variable Portfolio Global Strategic Income Fund
Columbia Variable Portfolio Government Money Market Fund
Columbia Variable Portfolio High Yield Bond Fund
Columbia Variable Portfolio Income Opportunities Fund
Columbia Variable Portfolio Intermediate Bond Fund
Columbia Variable Portfolio Large Cap Growth Fund
Columbia Variable Portfolio Large Cap Index Fund
Columbia Variable Portfolio Limited Duration Credit Fund
Columbia Variable Portfolio Mid Cap Growth Fund
Columbia Variable Portfolio Overseas Core Fund
Columbia Variable Portfolio Select Large Cap Equity Fund
Columbia Variable Portfolio Select Large Cap Value Fund
Columbia Variable Portfolio Select Mid Cap Value Fund
Columbia Variable Portfolio Select Small Cap Value Fund
Columbia Variable Portfolio Seligman Global Technology Fund
Columbia Variable Portfolio U.S. Equities Fund
Columbia Variable Portfolio U.S. Government Mortgage Fund
CTIVP American Century Diversified Bond Fund
CTIVP AQR International Core Equity Fund
CTIVP BlackRock Global Inflation-Protected Securities Fund
CTIVP CenterSquare Real Estate Fund
CTIVP DFA International Value Fund
CTIVP Loomis Sayles Growth Fund
CTIVP Los Angeles Capital Large Cap Growth Fund
CTIVP MFS® Value Fund
CTIVP Morgan Stanley Advantage Fund
CTIVP T. Rowe Price Large Cap Value Fund
CTIVP TCW Core Plus Bond Fund
CTIVP Victory Sycamore Established Value Fund
CTIVP Wells Fargo Short Duration Government Fund
CTIVP Westfield Mid Cap Growth Fund
CTIVP William Blair International Leaders Fund
Variable Portfolio Aggressive Portfolio
Variable Portfolio Columbia Wanger International Equities Fund
Variable Portfolio Conservative Portfolio
Variable Portfolio Managed Volatility Moderate Growth Fund
Variable Portfolio Moderate Portfolio
Variable Portfolio Moderately Aggressive Portfolio
Variable Portfolio Moderately Conservative Portfolio
Variable Portfolio Partners Core Bond Fund
Variable Portfolio Partners Core Equity Fund
Variable Portfolio Partners Small Cap Growth Fund
Variable Portfolio Partners Small Cap Value Fund
Shares of each Series established in this Section 6 shall have the following rights and preferences relative to Shares of each other Series, and Shares of each class of a Multi-Class Series shall have such rights and preferences relative to other classes of the same Series as are set forth in the Declaration of Trust, together with such other rights and preferences relative to such other classes as are set forth in the Trust's Rule 18f-3 Plan, registration statement as from time to time amended, and any applicable resolutions of the Trustees establishing and designating such class of Shares.
The rest of this Section 6 remains unchanged.
The foregoing amendment is effective as of June 19, 2019.
[The remainder of this page intentionally left blank.]
IN WITNESS WHEREOF, the undersigned has signed this Amendment No. 24 to the Declaration of Trust on June 19, 2019.
/s/ George S. Batejan |
/s/ Catherine James Paglia |
George S. Batejan |
Catherine James Paglia |
/s/ Kathleen A. Blatz |
/s/ Anthony M. Santomero |
Kathleen A. Blatz |
Anthony M. Santomero |
/s/ Edward J. Boudreau, Jr. |
/s/ Minor M. Shaw |
Edward J. Boudreau, Jr. |
Minor M. Shaw |
/s/ Pamela G. Carlton |
/s/ William F. Truscott |
Pamela G. Carlton |
William F. Truscott |
/s/ Patricia M. Flynn |
/s/ Sandra Yeager |
Patricia M. Flynn |
Sandra Yeager |
/s/ Brian J. Gallagher |
|
Brian J. Gallagher |
|
Registered Agent: |
Corporation Service Company |
|
84 State Street |
|
Boston, MA 02109 |
AMENDMENT NO. 2
TO THE SUBADVISORY AGREEMENT
This Amendment No. 2 (the "Amendment"), made and entered into as of October 21, 2019, is made a part of the Subadvisory Agreement between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company ("Investment Manager") and Loomis, Sayles & Company, L.P., a Delaware limited partnership ("Subadviser"), dated January 15, 2014, as amended November 19, 2015 (the "Agreement").
WHEREAS, Investment Manager and Subadviser desire to amend the Agreement, including Schedule A.
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1.Compensation of Subadviser. Section 4 of the Agreement shall be, and hereby is deleted and replaced with the following:
For the services provided and the expenses assumed pursuant to this Agreement, Investment Manager will pay to Subadviser, effective from the date of this Agreement, a fee which shall be determined daily and paid monthly, on or before the last business day of the next succeeding calendar month, at the annual rates set forth in the attached Schedule A which Schedule can be modified from time to time upon mutual agreement of the parties to reflect changes in annual rates, subject to appropriate approvals required by the 1940 Act, if any. If this Agreement becomes effective or terminates before the end of any month, the fee for the period from the effective date to the end of the month or from the beginning of such month to the date of termination, as the case may be, shall be prorated according to the proportion that such portion of the month bears to the full month in which such effectiveness or termination occurs. During the term of this Agreement, Subadviser will pay all expenses incurred by it in connection with its activities under this Agreement other than costs in connection with the purchase or sale of securities and other assets (including brokerage commissions, if any) for the Fund.
2.Schedule A. Schedule A to the Agreement shall be, and hereby is, deleted and replaced with the Schedule A attached hereto.
3.The following shall be, and is hereby added as Section 21 to the Agreement:
No Third-Party Beneficiaries. The Fund is intended to be a third party beneficiary of this Agreement. For the avoidance of doubt, and without in any way implying that there are any other third-party beneficiaries to the Agreement or any other agreement with respect to the Trust or any of its series, no person other than the Investment Manager and the Subadviser is a party to this Agreement or shall be entitled to any right or benefit arising under or in respect of this Agreement (with the exception of the Fund), and there are no other third-party beneficiaries of this Agreement. Without limiting the generality of the foregoing, nothing in this Agreement is intended to, or shall be read to, (i) create in any other person (including without limitation any shareholder of any Fund) any direct, indirect, derivative, or other rights against the Investment Manager or Subadviser, or (ii) create or give rise to any duty or obligation on the part of the Investment Manager or Subadviser (including without limitation any fiduciary duty) to any person other than the Fund, all of which rights, benefits, duties, and obligations are hereby expressly excluded.
IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment |
Loomis, Sayles & Company, L.P. |
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Advisers, LLC |
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By: |
/s/ David Weiss |
By: |
/s/ Lauren B. Pitalis |
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Signature |
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Signature |
Name: |
David Weiss |
Name: |
Lauren B. Pitalis |
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Printed |
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Printed |
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Vice President, Director of |
Title: |
Assistant Secretary |
Title: |
Client Intake |
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AMENDMENT NO. 2
TO THE SUBADVISORY AGREEMENT
[SCHEDULE LISTING FUND AND FEE RATE OMITTED]
AMENDMENT NO. 3
TO THE SUBADVISORY AGREEMENT
This Amendment No. 3 (the "Amendment"), made and entered into as of February 5, 2020, is made a part of the Subadvisory Agreement between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company ("Investment Manager") and Loomis, Sayles & Company, L.P., a Delaware limited partnership ("Subadviser"), dated January 15, 2014, as amended November 19, 2015 and October 21, 2019 (the "Agreement").
WHEREAS, Investment Manager and Subadviser desire to amend the Agreement, including Schedule A thereto.
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1.Schedule A. Schedule A to the Agreement shall be, and hereby is, deleted and replaced with the Schedule A attached hereto.
[REMAINDER OF THIS PAGE HAS BEEN LEFT BLANK INTENTIONALLY]
Document Number: 359328
IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment |
Loomis, Sayles & Company, L.P. |
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Advisers, LLC |
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By: |
/s/ David Weiss |
By: |
/s/ Lauren B. Pitalis |
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Signature |
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Signature |
Name: |
David Weiss |
Name: |
Lauren B. Pitalis |
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Printed |
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Printed |
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Vice President, Director of |
Title: |
Assistant Secretary |
Title: |
Client Intake |
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Document Number: 359328
AMENDMENT NO. 3
TO THE SUBADVISORY AGREEMENT
SCHEDULE A AS OF APRIL 1, 2020
[SCHEDULE LISTING FUND AND FEE RATE OMITTED]
Document Number: 359328
AMENDMENT NO. 2
TO THE SUBADVISORY AGREEMENT
This Amendment No. 2 (the "Amendment"), made and entered into as of November 20, 2019, is made a part of the Subadvisory Agreement between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company ("Investment Manager") and Los Angeles Capital Management and Equity Research, Inc., a California corporation (Subadviser"), dated February 15, 2017, as amended May 31, 2018 (the "Agreement").
WHEREAS, Investment Manager and Subadviser desire to amend the Agreement, including Schedule A thereto.
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1.Schedule A. Schedule A to the Agreement shall be, and hereby is, deleted and replaced with the Schedule A attached hereto.
[REMAINDER OF THIS PAGE HAS BEEN LEFT BLANK INTENTIONALLY]
IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment |
Los Angeles Capital Management and |
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Advisers, LLC |
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Equity Research, Inc. |
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By: |
/s/ David Weiss |
By: |
/s/ Thomas Stevens |
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Signature |
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Signature |
Name: |
David Weiss |
Name: |
Thomas Stevens |
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Printed |
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Printed |
Title: |
Assistant Secretary |
Title: |
CEO |
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AMENDMENT NO. 2
TO THE SUBADVISORY AGREEMENT
SCHEDULE A
[SCHEDULE LISTING FUND AND FEE RATE OMITTED]
AMENDMENT NO. 1
TO THE SUBADVISORY AGREEMENT
This Amendment No. 1 (the "Amendment"), made and entered into as of November 1, 2019, is made a part of the Subadvisory Agreement between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company ("Investment Manager") and TCW Investment Management Company LLC, a Delaware limited liability company (formerly TCW Investment Management Company) ("Subadviser"), dated January 15, 2014 (the "Agreement").
WHEREAS, Investment Manager and Subadviser desire to amend the Agreement, including Schedule A.
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1.Compensation of Subadviser. Section 4 of the Agreement shall be, and hereby is deleted and replaced with the following:
For the services provided and the expenses assumed pursuant to this Agreement, Investment Manager will pay to Subadviser, effective from the date of this Agreement, a fee which shall be determined daily and paid monthly, on or before the last business day of the next succeeding calendar month, at the annual rates set forth in the attached Schedule A which Schedule can be modified from time to time upon mutual agreement of the parties to reflect changes in annual rates, subject to appropriate approvals required by the 1940 Act, if any. If this Agreement becomes effective or terminates before the end of any month, the fee for the period from the effective date to the end of the month or from the beginning of such month to the date of termination, as the case may be, shall be prorated according to the proportion that such portion of the month bears to the full month in which such effectiveness or termination occurs. During the term of this Agreement, Subadviser will pay all expenses incurred by it in connection with its activities under this Agreement other than costs in connection with the purchase or sale of securities and other assets (including brokerage commissions, if any) for the Fund.
2.Schedule A. Schedule A to the Agreement shall be, and hereby is, deleted and replaced with the Schedule A attached hereto.
3.The following shall be, and is hereby added as Section 23 to the Agreement:
Document Number: 354622
No Third-Party Beneficiaries. The Fund is intended to be a third party beneficiary of this Agreement. For the avoidance of doubt, and without in any way implying that there are any other third-party beneficiaries to the Agreement or any other agreement with respect to the Trust or any of its series, no person other than the Investment Manager and the Subadviser is a party to this Agreement or shall be entitled to any right or benefit arising under or in respect of this Agreement (with the exception of the Fund), and there are no other third-party beneficiaries of this Agreement. Without limiting the generality of the foregoing, nothing in this Agreement is intended to, or shall be read to, (i) create in any other person (including without limitation any shareholder of any Fund) any direct, indirect, derivative, or other rights against the Investment Manager or Subadviser, or (ii) create or give rise to any duty or obligation on the part of the Investment Manager or Subadviser (including without limitation any fiduciary duty) to any person other than the Fund, all of which rights, benefits, duties, and obligations are hereby expressly excluded.
Document Number: 354622
IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment |
TCW Investment Management |
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Advisers, LLC |
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Company LLC |
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By: |
/s/ David Weiss |
By: |
/s/ Patrick Dennis |
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Signature |
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Signature |
Name: |
David Weiss |
Name: |
Patrick Dennis |
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Printed |
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Printed |
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Senior Vice President |
Title: |
Assistant Secretary |
Title: |
Associate General Counsel |
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Document Number: 354622
AMENDMENT NO. 1
TO THE SUBADVISORY AGREEMENT
SCHEDULE A AS OF November 1, 2019
[SCHEDULE LISTING FUND AND FEE RATE OMITTED]
Document Number: 354622
AMENDMENT NO. 1
TO THE SUBADVISORY AGREEMENT
This Amendment No. 1 (the "Amendment"), made and entered into as of May 13, 2019, is made a part of the Subadvisory Agreement between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company ("Investment Manager") and Victory Capital Management Inc., a New York corporation ("Subadviser"), dated June 19, 2013 (the "Agreement").
WHEREAS, Investment Manager and Subadviser desire to amend the Agreement, including Schedule A.
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1.Compensation of Subadviser. Section 4 of the Agreement shall be, and hereby is deleted and replaced with the following:
For the services provided and the expenses assumed pursuant to this Agreement, Investment Manager will pay to Subadviser, effective from the date of this Agreement, a fee which shall be determined daily and paid monthly, on or before the last business day of the next succeeding calendar month, at the annual rates set forth in the attached Schedule A which Schedule can be modified from time to time upon mutual agreement of the parties to reflect changes in annual rates, subject to appropriate approvals required by the 1940 Act, if any. If this Agreement becomes effective or terminates before the end of any month, the fee for the period from the effective date to the end of the month or from the beginning of such month to the date of termination, as the case may be, shall be prorated according to the proportion that such portion of the month bears to the full month in which such effectiveness or termination occurs. During the term of this Agreement, Subadviser will pay all expenses incurred by it in connection with its activities under this Agreement other than costs in connection with the purchase or sale of securities and other assets (including brokerage commissions, if any) for the Fund.
2.Schedule A. Schedule A to the Agreement shall be, and hereby is, deleted and replaced with the Schedule A attached hereto.
3.The following shall be, and is hereby added as Section 21 to the Agreement:
No Third-Party Beneficiaries. The Fund is intended to be a third party beneficiary of this Agreement. For the avoidance of doubt, and without in any way implying that there are any other third-party beneficiaries to the Agreement or any other agreement with respect to the Trust or any of its series, no person other than the Investment Manager and the Subadviser is a party to this Agreement or shall be entitled to any right or benefit arising under or in respect of this Agreement (with the exception of the Fund), and there are no other third-party beneficiaries of this Agreement. Without limiting the generality of the foregoing, nothing in this Agreement is intended to, or shall be read to, (i) create in any other person (including without limitation any shareholder of any Fund) any direct, indirect, derivative, or other rights against the Investment Manager or Subadviser, or (ii) create or give rise to any duty or obligation on the part of the Investment Manager or Subadviser (including without limitation any fiduciary duty) to any person other than the Fund, all of which rights, benefits, duties, and obligations are hereby expressly excluded.
IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment |
Victory Capital Management Inc. |
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Advisers, LLC |
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By: |
By: |
/s/ Mike Policarpo |
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/s/ David Weiss |
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Signature |
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Signature |
Name: |
David Weiss |
Name: |
Mike Policarpo |
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Printed |
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Printed |
Title: |
Assistant Secretary |
Title: |
COO |
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AMENDMENT NO. 1
TO THE SUBADVISORY AGREEMENT
SCHEDULE A AS OF MAY 13, 2019
[SCHEDULE LISTING FUND AND FEE RATE OMITTED]
Distribution Agreement Schedules CFVST II
Schedule I
As of July 1, 2019
Columbia Funds Variable Series Trust II
Columbia Variable Portfolio Commodity Strategy Fund
Columbia Variable Portfolio Core Equity Fund
Columbia Variable Portfolio Disciplined Core Fund
Columbia Variable Portfolio Dividend Opportunity Fund
Columbia Variable Portfolio Emerging Markets Bond Fund
Columbia Variable Portfolio Emerging Markets Fund
Columbia Variable Portfolio Global Strategic Income Fund
Columbia Variable Portfolio Government Money Market Fund
Columbia Variable Portfolio High Yield Bond Fund
Columbia Variable Portfolio Income Opportunities Fund
Columbia Variable Portfolio Intermediate Bond Fund
Columbia Variable Portfolio Large Cap Growth Fund
Columbia Variable Portfolio Large Cap Index Fund
Columbia Variable Portfolio Limited Duration Credit Fund
Columbia Variable Portfolio Mid Cap Growth Fund
Columbia Variable Portfolio Overseas Core Fund
Columbia Variable Portfolio Select Large Cap Equity Fund
Columbia Variable Portfolio Select Large Cap Value Fund
Columbia Variable Portfolio Select Mid Cap Value Fund
Columbia Variable Portfolio Select Small Cap Value Fund
Columbia Variable Portfolio Seligman Global Technology Fund
Columbia Variable Portfolio U.S. Equities Fund
Columbia Variable Portfolio U.S. Government Mortgage Fund
CTIVP® American Century Diversified Bond Fund
CTIVP® AQR International Core Equity Fund
CTIVP® BlackRock Global Inflation-Protected Securities Fund
CTIVP® CenterSquare Real Estate Fund
CTIVP® DFA International Value Fund
CTIVP® Loomis Sayles Growth Fund
CTIVP® Los Angeles Capital Large Cap Growth Fund
CTIVP® MFS® Value Fund
CTIVP® Morgan Stanley Advantage Fund
CTIVP® T. Rowe Price Large Cap Value Fund
CTIVP® TCW Core Plus Bond Fund
CTIVP® Victory Sycamore Established Value Fund
CTIVP® Wells Fargo Short Duration Government Fund
CTIVP® Westfield Mid Cap Growth Fund
CTIVP® William Blair International Leaders Fund
Variable Portfolio Aggressive Portfolio
Variable Portfolio Columbia Wanger International Equities Fund
Variable Portfolio Conservative Portfolio
Variable Portfolio Managed Volatility Moderate Growth Fund
Variable Portfolio Moderate Portfolio
Variable Portfolio Moderately Aggressive Portfolio
Variable Portfolio Moderately Conservative Portfolio
Variable Portfolio Partners Core Bond Fund
Variable Portfolio Partners Core Equity Fund
Variable Portfolio Partners Small Cap Growth Fund
Variable Portfolio Partners Small Cap Value Fund
342509 v.7
Distribution Agreement Schedules CFVST II
IN WITNESS THEREOF, the parties hereto have executed the foregoing Schedule I as of June 19, 2019.
COLUMBIA FUNDS VARIABLE SERIES TRUST II on behalf of its respective Funds, if any
By: /s/ Christopher O. Petersen
Name: Christopher O. Petersen
Title: President
COLUMBIA MANAGEMENT INVESTMENT
DISTRIBUTORS, INC.
By: |
/s/ Daniel J. Beckman |
Name: |
Daniel J. Beckman |
Title: |
Vice President and Head of U.S. Retail Product |
342509 v.7
Distribution Agreement Schedules CFVST II
SCHEDULE II
COMPENSATION
COMPENSATION TO DISTRIBUTOR. In connection with the distribution of Shares, Distributor will be entitled to receive payments pursuant to any Distribution Plan and related agreement from time to time in effect between any Fund and Distributor or any particular class of shares of a Fund ("12b-1 Plan").
Approved: Sept. 7, 2010
342509 v.7
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
We hereby consent to the incorporation by reference in this Registration Statement on Form N-1A of Columbia Funds Variable Series Trust II of our reports dated as listed in Appendix A, relating to the financial statements and financial highlights, which appear in the Annual Reports on Form N-CSR of the funds indicated in Appendix A for the year ended December 31, 2019. We also consent to the references to us under the headings "Financial Highlights", "Independent Registered Public Accounting Firm" and "Organization and Management of Wholly-Owned Subsidiaries" in such Registration Statement.
/s/PricewaterhouseCoopers LLP Minneapolis, Minnesota
April 27, 2020
Appendix A
Fund Name
Reports Dated 2/21/2020
CTIVP - Loomis Sayles Growth Fund
Columbia Variable Portfolio - Government Money Market Fund
Columbia Variable Portfolio - Overseas Core Fund
Columbia Variable Portfolio - High Yield Bond Fund
Columbia Variable Portfolio - Large Cap Growth Fund
Columbia Variable Portfolio - Dividend Opportunity Fund
Columbia Variable Portfolio - U.S. Government Mortgage Fund
Columbia Variable Portfolio - Large Cap Index Fund
Columbia Variable Portfolio - Emerging Markets Fund
Columbia Variable Portfolio - Mid Cap Growth Fund
Columbia Variable Portfolio - Select Large Cap Value Fund
Columbia Variable Portfolio - Income Opportunities Fund
Columbia Variable Portfolio - Select Mid Cap Value Fund
Columbia Variable Portfolio - Limited Duration Credit Fund
Columbia Variable Portfolio - Disciplined Core Fund
Columbia Variable Portfolio - Balanced Fund
Columbia Variable Portfolio - Select Small Cap Value Fund
Columbia Variable Portfolio - Commodity Strategy Fund
Columbia Variable Portfolio - Core Equity Fund
Columbia Variable Portfolio - Emerging Markets Bond Fund
Columbia Variable Portfolio - Global Strategic Income Fund
Columbia Variable Portfolio - Intermediate Bond Fund
Columbia Variable Portfolio - Select Large Cap Equity Fund
Columbia Variable Portfolio - Seligman Global Technology Fund
CTIVP - BlackRock Global Inflation-Protected Securities Fund
CTIVP - Victory Sycamore Established Value Fund
Variable Portfolio - Aggressive Portfolio
Variable Portfolio - Conservative Portfolio
Variable Portfolio - Managed Volatility Moderate Growth Fund
Variable Portfolio - Moderate Portfolio
Variable Portfolio - Moderately Aggressive Portfolio
Variable Portfolio - Moderately Conservative Portfolio
Variable Portfolio - Partners Core Equity Fund
Variable Portfolio - Partners Small Cap Value Fund
Reports Dated 2/24/2020
CTIVP - American Century Diversified Bond Fund
Variable Portfolio Partners International Core Equity Fund (CTIVP - AQR International Core Equity Fund) CTIVP - CenterSquare Real Estate Fund
Variable Portfolio Partners International Value Fund (CTIVP - DFA International Value Fund) CTIVP - Los Angeles Capital Large Cap Growth Fund
CTIVP - MFS Value Fund
CTIVP - Morgan Stanley Advantage Fund CTIVP - T. Rowe Price Large Cap Value Fund CTIVP - TCW Core Plus Bond Fund
CTIVP - Wells Fargo Short Duration Government Fund CTIVP - Westfield Mid Cap Growth Fund
Variable Portfolio Partners International Growth Fund (CTIVP - William Blair International Leaders Fund) Variable Portfolio - Partners Core Bond Fund
Variable Portfolio - Partners Small Cap Growth Fund
12b-1 Schedule – CFVST II
Schedule A
Effective July 1, 2019
|
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Classes |
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Class 2 |
Class 3 |
Class 4 |
Funds |
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Columbia Funds Variable Series Trust II |
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Columbia Variable Portfolio – Balanced Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Commodity Strategy Fund |
Class 2 |
-- |
-- |
Columbia Variable Portfolio – Disciplined Core Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Dividend Opportunity Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Emerging Markets Bond Fund |
Class 2 |
-- |
-- |
Columbia Variable Portfolio – Emerging Markets Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Global Strategic Income Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Government Money Market Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – High Yield Bond Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Income Opportunities Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Intermediate Bond Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Large Cap Growth Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Large Cap Index Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Limited Duration Credit Fund |
Class 2 |
-- |
-- |
Columbia Variable Portfolio – Mid Cap Growth Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Overseas Core Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Select Large Cap Equity Fund |
Class 2 |
-- |
-- |
Columbia Variable Portfolio – Select Large Cap Value Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Select Mid Cap Value Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio – Select Small Cap Value Fund |
Class 2 |
Class 3 |
-- |
Columbia Variable Portfolio - Seligman Global Technology Fund |
Class 2 |
-- |
-- |
Columbia Variable Portfolio – U.S. Equities Fund |
Class 2 |
-- |
-- |
Columbia Variable Portfolio - U.S. Government Mortgage Fund |
Class 2 |
Class 3 |
-- |
CTIVP® – American Century Diversified Bond Fund |
Class 2 |
-- |
-- |
CTIVP® – AQR International Core Equity Fund |
Class 2 |
-- |
-- |
CTIVP® – BlackRock Global Inflation-Protected Securities Fund |
Class 2 |
Class 3 |
-- |
CTIVP® – CenterSquare Real Estate Fund |
Class 2 |
-- |
-- |
CTIVP® – DFA International Value Fund |
Class 2 |
-- |
-- |
CTIVP® – Loomis Sayles Growth Fund |
Class 2 |
-- |
-- |
CTIVP® – Los Angeles Capital Large Cap Growth Fund |
Class 2 |
-- |
-- |
CTIVP® – MFS® Value Fund |
Class 2 |
-- |
-- |
CTIVP® – Morgan Stanley Advantage Fund |
Class 2 |
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CTIVP® – T. Rowe Price Large Cap Value Fund |
Class 2 |
-- |
-- |
CTIVP® – TCW Core Plus Bond Fund |
Class 2 |
-- |
-- |
CTIVP® – Victory Sycamore Established Value Fund |
Class 2 |
Class 3 |
-- |
CTIVP® – Wells Fargo Short Duration Government Fund |
Class 2 |
-- |
-- |
CTIVP® – Westfield Mid Cap Growth Fund |
Class 2 |
-- |
-- |
CTIVP® – Willaim Blair International Leaders Fund |
Class 2 |
-- |
-- |
Variable Portfolio – Aggressive Portfolio |
Class 2 |
-- |
Class 4 |
Variable Portfolio – Columbia Wanger International Equities Fund |
Class 2 |
-- |
-- |
Variable Portfolio – Conservative Portfolio |
Class 2 |
-- |
Class 4 |
Variable Portfolio – Managed Volatility Moderate Growth Fund |
Class 2 |
-- |
-- |
Variable Portfolio – Moderate Portfolio |
Class 2 |
-- |
Class 4 |
Variable Portfolio – Moderately Aggressive Portfolio |
Class 2 |
-- |
Class 4 |
Variable Portfolio – Moderately Conservative Portfolio |
Class 2 |
-- |
Class 4 |
Variable Portfolio – Partners Core Bond Fund |
Class 2 |
-- |
-- |
Variable Portfolio – Partners Core Equity Fund |
Class 2 |
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Variable Portfolio – Partners Small Cap Growth Fund |
Class 2 |
-- |
-- |
Variable Portfolio – Partners Small Cap Value Fund |
Class 2 |
Class 3 |
-- |
342520 v.8
12b-1 Schedule – CFVST II
Fee Schedule
The maximum fee for services under this Plan and Agreement shall be the lesser of the amount of expenses eligible for reimbursement (including any unreimbursed expenses) or a rate equal on an annual basis to the percentage of the average daily net assets of the Fund attributable to the applicable class as set forth in the table below (the "Lesser of Methodology"). The Lesser of Methodology shall be determined and applied on a quarterly basis by computing the amount of actual fees and expenses accrued during the prior quarter (for each share class of each Fund) that were eligible to be paid under Section 3 of the Plan (i.e., the "expenses eligible for reimbursement") and comparing that amount to the flat rate for the applicable Class. If the flat rate exceeds the expenses eligible for reimbursement, then, based on the Lesser of Methodology, the maximum 12b-1 fee amount accrued for such Class is applied on a going forward basis to reflect the actual amount of expenses eligible for reimbursement for the prior quarter. This determination and calculation is re-applied each subsequent quarter. The frequency of application of the methodology (currently, quarterly) may be revised by the Distributor at any time, after consultation with the Board.
Class |
Fee |
Class 2 |
0.25% |
Class 3 |
0.125% |
Class 4 |
0.25% |
Payments under the Plan and Agreement shall be made within five (5) business days after the last day of each month. At the end of each calendar year, Columbia Management Investment Distributors shall furnish a declaration setting out the actual expenses it has paid and accrued. Any money that has been paid in excess of the amount of these expenses shall be returned to the Funds.
342520 v.8
12b-1 Schedule – CFVST II
IN WITNESS THEREOF, the parties hereto have executed the foregoing Schedule A as of June 19, 2019.
COLUMBIA FUNDS VARIABLE SERIES TRUST II
By: /s/ Christopher O.Petersen
Name: Christopher O. Petersen
Title: President
COLUMBIA MANAGEMENT INVESTMENT DISTRIBUTORS, INC.
By: |
__/s/ Daniel J. Beckman |
Title: |
Vice President and Head of U.S. Retail Product |
342520 v.8
18f-3 Plan CFVST II
AMENDED AND RESTATED
RULE 18f-3 MULTI-CLASS PLAN
I.Introduction.
Pursuant to Rule 18f-3 under the Investment Company Act of 1940, as amended (the "1940 Act"), this Rule 18f-3 Multi-Class Plan ("Plan") sets forth the methods for allocating fees and expenses among the classes of shares ("Shares") in the investment portfolios (the "Funds") of Columbia Funds Variable Series Trust II (the "Trust"). Among other things, this Plan identifies expenses that may be allocated to a particular class of Shares to the extent that they are actually incurred in a different amount by the class or relate to a different kind or degree of services provided to the class. In addition, this Plan sets forth the maximum distribution fees, maximum shareholder servicing fees, maximum shareholder administration fees, conversion features, exchange privileges, other shareholder services and transfer agency fees, if any, applicable or allocated to each class of Shares of the Trust.
The Trust is an open-end series investment company registered under the 1940 Act, the Shares of which are registered on Form N-1A under the Securities Act of 1933. The Trust offers multiple classes of Shares in its Funds pursuant to the provisions of Rule 18f-3 and this Plan.
Each Fund and the classes of Shares representing interests in the Fund it issues are set forth in Schedule A hereto. Schedule A shall be updated by officers of the Trust from time to time as necessary to reflect the current classes and Funds offered by the Trust.
II.Allocation of Expenses.
1.Except as otherwise set forth herein or as may from time to time be specifically approved by board of trustees of the Registrant (the Trustees), all expenses of each Fund shall be allocated proportionately among the classes of such Fund pro rata based on the relative net assets of each class. Pursuant to Rule 18f-3, the Trust shall allocate to each class of Shares in a Fund any fees and expenses incurred by the Trust in connection with the distribution and/or the provision of shareholder services to holders of such class of Shares under any distribution plan, shareholder servicing plan and/or plan administration agreement (a "Distribution/Shareholder Servicing Plan").
2.In addition, pursuant to Rule 18f-3, the Trust may allocate to a particular class of Shares the following fees and expenses, if any, but only to the extent they relate to (as defined below) the particular class of Shares:
(i)transfer agency fees and expenses identified by the Registrant's transfer agent or officers as being fees and expenses that relate to such class of Shares;
(ii)printing and postage expenses of preparing and distributing materials such as shareholder reports, prospectuses, reports and proxies to current shareholders of such class of Shares or to regulatory agencies that relate to such class of Shares;
302595 v.16
(iii)blue sky registration or qualification fees that relate to such class of Shares;
(iv)Securities and Exchange Commission registration fees that relate to such class of Shares;
(v)expenses of administrative personnel and services (including, but not limited to, those of a portfolio accountant, custodian or dividend paying agent charged with calculating net asset values and determining or paying distributions) as required to support the shareholders of such class of Shares;
(vi)litigation or other legal expenses that relate to such class of Shares;
(vii)fees of the Trustees of the Trust incurred as a result of issues that relate to such class of Shares;
(viii)independent accountants' fees that relate to such class of Shares; and
(ix)any other fees and expenses that relate to such class of Shares.
Notwithstanding the foregoing, the Trust may not allocate advisory or custodial fees or other expenses related to the management of a Fund's assets to a particular class, except that the Trust may cause a class to pay a different advisory fee to the extent that any difference in amount paid is the result of the application of the same performance fee provisions, if any, in the advisory contract of the Fund to the different investment performance of each class.
3.For all purposes under this Plan, fees and expenses "that relate to" a class of
Shares are those fees and expenses that are actually incurred in a different amount by the class or that relate to a different kind or degree of services provided to the class. The officers of the Trust shall have the authority to determine, to the extent permitted by applicable law or regulation and/or U.S. Securities and Exchange Commission guidance, whether any or all of the fees and expenses described in paragraph 2 above should be allocated to a particular class of Shares. The Treasurer, any Deputy or Assistant Treasurer, or another appropriate officer of the Trust shall periodically or as frequently as requested by the Board report to independent Trustees regarding any such allocations.
4.For all purposes under this Plan, "Daily Dividend Fund" means any Fund that has a policy of declaring distributions of net investment income daily, including any money market fund that determines net asset value using the amortized cost method permitted by Rule 2a-7 under the 1940 Act.
5.Income and any expenses of Daily Dividend Funds that are not allocated to a particular class of any such Fund pursuant to this Plan shall be allocated to each class of the Fund on the basis of the net assets of that class in relation to the net assets of the Fund, excluding the value of subscriptions receivable (the "Settled Shares Method").
Realized and unrealized capital gains and losses of Daily Dividend Funds that are not allocated to a particular class of any such Fund pursuant to this Plan shall be allocated to each
302595 v.17
class of the Fund on the basis of the net assets of that class in relation to the net assets of the Fund (the "Relative Net Assets Method").
6.Income, realized and unrealized capital gains and losses, and any expenses of Funds that are not Daily Dividend Funds that are not allocated to a particular class of any such Fund pursuant to this Plan shall be allocated to each class of the Fund on the Relative Net Assets Method.
7.Pursuant to the shareholder service agreement, each Share class is subject to service fee up to fee set forth in the agreement. There is no transfer agency service fees for Columbia Variable Portfolio Core Equity Fund.
8.Pursuant to the shareholder service agreement, each Share class is subject to service fee up to fee set forth in the agreement.
9.In certain cases, a Fund service provider may waive or reimburse all or a portion of the expenses of a specific class of Shares of the Fund. The applicable service provider shall report to the Board of Trustees regarding any such waivers or reimbursements, including why they are consistent with the fair and equitable treatment of shareholders of all classes.
III.Class Arrangements.
The following summarizes the maximum initial sales charges, contingent deferred sales
charges, maximum distribution fees, maximum shareholder servicing fees, maximum plan administration and/or shareholder administration fees, if any, conversion features, exchange privileges and other shareholder service fees, if any, applicable or allocated to each class of Shares of the Trust. Additional details regarding such fees and services are set forth in the relevant Fund's (or Funds') current prospectus(es) and statement of additional information.
1.Class 1 Shares
A.Maximum Initial Sales Charge: None
B.Maximum Contingent Deferred Sales Charge: None
C.Maximum Distribution/Shareholder Servicing Fees: None
D.Conversion Features/Exchange Privileges: Class 1 Shares of a Fund shall have such conversion features and exchange privileges, if any, as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
E.Other Shareholder Services: Class 1 Shares of a Fund shall have such arrangements for shareholder services as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
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2.Class 2 Shares
A.Initial Sales Charge: None
B.Maximum Contingent Deferred Sales Charge: None
C.Maximum Distribution/Shareholder Servicing Fees: Class 2 Shares may pay distribution and service fees pursuant to a Distribution/Shareholder Servicing Plan as described in the prospectuses as from time to time in effect. Such distribution fees may be in amounts up to 0.25% per annum of the average daily net assets attributable to such class.
D.Conversion Features/Exchange Privileges: Class 2 Shares of a Fund shall have such conversion features and exchange privileges, if any, as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
E.Other Shareholder Services: Class 2 Shares of a Fund shall have such arrangements for shareholder services as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
3.Class 3 Shares
A.Initial Sales Charge: None
B.Maximum Contingent Deferred Sales Charge: None
C.Maximum Distribution/Shareholder Servicing Fees: Pursuant to a Distribution/Shareholder Servicing Plan, Class 3 Shares of each Fund may pay distribution fees of up to 0.125% of the average daily net assets of such Shares.
D.Conversion Features/Exchange Privileges: Class 3 Shares of a Fund shall have such conversion features and exchange privileges, if any, as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
E.Other Shareholder Services: Class 3 Shares of a Fund shall have such arrangements for shareholder services as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
4.Class 4 Shares
A.Initial Sales Charge: None
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B.Maximum Contingent Deferred Sales Charge: None
C.Maximum Distribution/Shareholder Servicing Fees: Pursuant to a Distribution/Shareholder Servicing Plan, Class 4 Shares of each Fund may pay distribution fees of up to 0.25% of the average daily net assets of such Shares.
D.Conversion Features/Exchange Privileges: Class 4 Shares of a Fund shall have such conversion features and exchange privileges, if any, as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
E.Other Shareholder Services: Class 4 Shares of a Fund shall have such arrangements for shareholder services as are determined by or ratified by the Board of Trustees of the Trust and described in the then-current prospectus for such Shares of such Fund.
IV. Board Review.
The Board of Trustees of the Trust shall review this Plan, including the application of the Relative Net Assets Method and the Settled Shares Method to the Funds, as frequently as it deems necessary. Prior to any material amendment(s) to this Plan, the Board of Trustees of the Trust, including a majority of the Trustees who are not interested persons of the Trust, shall find that the Plan, as proposed to be amended (including any proposed amendments to the method of allocating class and/or Fund expenses), is in the best interests of each class of Shares of the Fund individually and the Fund as a whole. In considering whether to approve any proposed amendment(s) to the Plan, the Board of Trustees of the Trust shall request and evaluate such information as they consider reasonably necessary to evaluate the proposed amendment(s) to the Plan.
Adopted: |
September 7, 2010 |
Amended and Restated: |
April 17, 2013 |
Amended and Restated |
April 11, 2014 |
Amended and Restated |
May 1, 2015 |
Amended and Restated |
May 1, 2016 |
Amended and Restated |
May 1, 2017 |
Amended and Restated |
July 1, 2017 |
Amended and Restated |
November 15, 2017 |
Amended and Restated |
May 1, 2018 |
Amended and Restated |
September 14, 2018 |
Amended and Restated |
June 19, 2019 |
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Schedule A
Effective July 1, 2019
Funds and Authorized Classes of Shares
The Funds are authorized to issue those classes of Shares representing interests in the Funds as indicated in the following table:
FUNDS WITH CLASSES 1, 2, 3 AND 4
|
|
|
Classes |
|
|
Funds |
Class 1 |
Class 2 |
|
Class 3 |
Class 4 |
Columbia Funds Variable Series Trust II |
|
|
|
|
|
Columbia Variable Portfolio Balanced Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Government Money Market Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Commodity Strategy Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Columbia Variable Portfolio Disciplined Core Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Dividend Opportunity Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Emerging Markets Bond Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Columbia Variable Portfolio Emerging Markets Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Global Strategic Income Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio High Yield Bond Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Income Opportunities Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Intermediate Bond Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Large Cap Growth Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Large Cap Index Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Limited Duration Credit Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Columbia Variable Portfolio Mid Cap Growth Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Overseas Core Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Select Large Cap Equity Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Columbia Variable Portfolio Select Large Cap Value Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Select Mid Cap Value Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio Select Small Cap Value Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Columbia Variable Portfolio - Seligman Global Technology Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Columbia Variable Portfolio U.S. Equities Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Columbia Variable Portfolio U.S. Government Mortgage Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
CTIVP® American Century Diversified Bond Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® AQR International Core Equity Fund |
Class 1 |
Class 2 |
|
-- |
-- |
|
A-1 |
|
|
|
|
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|
|
|
Classes |
|
|
Funds |
Class 1 |
Class 2 |
|
Class 3 |
Class 4 |
CTIVP® BlackRock Global Inflation-Protected Securities Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
CTIVP® CenterSquare Real Estate Fund |
Class 1 |
Class 2 |
|
-- |
|
CTIVP® DFA International Value Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® Loomis Sayles Growth Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® Los Angeles Capital Large Cap Growth Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® MFS® Value Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® Morgan Stanley Advantage Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® TCW Core Plus Bond Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® T. Rowe Price Large Cap Value Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® Victory Sycamore Establish Value Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
CTIVP® Wells Fargo Short Duration Government Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® Westfield Mid Cap Growth Fund |
Class 1 |
Class 2 |
|
-- |
-- |
CTIVP® William Blair International Leaders Fund |
Class 1 |
Class 2 |
|
-- |
|
Variable Portfolio Aggressive Portfolio |
Class 1 |
Class 2 |
|
-- |
Class 4 |
Variable Portfolio Columbia Wanger International Equities Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Variable Portfolio Conservative Portfolio |
Class 1 |
Class 2 |
|
-- |
Class 4 |
Variable Portfolio Managed Volatility Moderate Growth Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Variable Portfolio Moderate Portfolio |
Class 1 |
Class 2 |
|
-- |
Class 4 |
Variable Portfolio Moderately Aggressive Portfolio |
Class 1 |
Class 2 |
|
-- |
Class 4 |
Variable Portfolio Moderately Conservative Portfolio |
Class 1 |
Class 2 |
|
-- |
Class 4 |
Variable Portfolio Partners Core Bond Fund |
Class 1 |
Class 2 |
|
-- |
|
Variable Portfolio Partners Core Equity Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
Variable Portfolio Partners Small Cap Growth Fund |
Class 1 |
Class 2 |
|
-- |
-- |
Variable Portfolio Partners Small Cap Value Fund |
Class 1 |
Class 2 |
|
Class 3 |
-- |
302595 v.17
Code of
Snapshot of the Policy
The Code of Ethics is a comprehensive policy which provides the standards for personal investing by American Century Investments (ACI) employees. Each employee has a Code of Ethics classification based on their job responsibilities and the ability to access nonpublic information about ACI client portfolios' security holdings and trading activities. The restrictions on personal investing contained in the Code vary by classification. The Code of Ethics also applies to accounts and securities that ACI employees beneficially own (i.e. owned by immediate family sharing your household, your domestic partner, or those you have power of attorney over, etc.).
It is important that you understand the Code and the restrictions on investing in personal securities and reportable mutual funds. This page contains a summary of the Code requirements. Please review the full text of the Code to fully understand your responsibilities. Contact Compliance if you have questions about the policy and how it applies to your situation. The Code of Ethics system (http://coe/) is the primary tool for performing your duties under the Code. All reporting and preclearance is performed in the Code of Ethics system.
Requirements for All Employees
Non-Access Persons, Access Persons, Investment Persons, and Portfolio Persons must
∙Place our client's interest first
∙Comply with federal securities laws
∙Report violations to Compliance
∙Acknowledge that you have read and understand the Code of Ethics
∙Disclose reportable brokerage accounts and reportable mutual fund accounts
∙Transfer reportable brokerage accounts to a broker that provides electronic trade confirmations (See Schedule C).
∙Comply with short-term trading restrictions for ACI client portfolios.
∙Obtain written approval to enter into an arrangement or agreement that could create a conflict of interest with ACI activities (i.e. serving on the board of directors of a publicly traded company).
Requirements for Access Persons, Investment and Portfolio Persons
Access Persons, Investment Persons, Portfolio Persons must
∙Disclose holdings within 10 days of designation and annually, thereafter
∙Disclose personal security transactions on a quarterly basis
∙Disclose conflicts of interest annually
∙Obtain approval (preclearance) to trade in reportable securities
Trading Prohibitions
∙Investment Persons and Portfolio Persons cannot participate in an Initial Public Offering.
∙Investment Persons and Portfolio Persons cannot profit on short-term reportable security trades within 60 calendar days.
∙Portfolio Persons cannot trade within seven days before and after transactions of a fund you manage.
∙Portfolio Persons cannot sell a security which is held by your assigned fund or buy a security held as a short position in your assigned funds.
Policy updated: August 21, 2019
1
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Table of Contents
APPENDIX 3: CODE-EXEMPT SECURITIES ..............................................................................................
Policy updated: August 21, 2019
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Code of
Purpose of Code
The Code of Ethics guides the personal investment activities of American Century Investments (ACI) employees (including full and part-time employees, contract and temporary employees, officers and directors), and members of their immediate family.1 The Code of Ethics aids in the elimination and detection of personal securities transactions by employees that might be viewed as fraudulent or might conflict with the interests of our client portfolios. Such transactions may include:
∙the misuse of client trading information for personal benefit (including so-called "front-running"),
∙the misappropriation of investment opportunities that may be appropriate for client portfolios,
∙and excessive personal trading that may affect our ability to provide services to our clients. Violations of this Code must be promptly reported to the Chief Compliance Officer.
Why Do We Have a Code of Ethics?
A.Investors have placed their trust in ACI
As an investment adviser, ACI is entrusted with the assets of our clients for investment purposes. Our employees' personal trading activities and the administration of the Code are governed by these general fiduciary principles:
∙The interests of our clients must be placed before our own.
∙Any personal securities transactions must be conducted consistent with this Code and in a manner as to avoid even the appearance of a conflict of interest.
Complying with these principles is how we earn and keep our clients' trust. To protect this trust, we will hold ourselves to the highest ethical standards.
B.ACI wants to give you flexible investing options
Management believes that ACI's own mutual funds and other pooled investment vehicles provide a broad range of investment alternatives in virtually every segment of the securities market. We encourage ACI employees to use these vehicles for their personal investments. We do not encourage active trading by our employees. We recognize, however, that individual needs differ and that there are other attractive investment opportunities. As a result, this Code is intended to give you and your family flexibility to invest, without jeopardizing relationships with our clients.
Our employees are able to undertake personal transactions in stocks and other individual securities subject to the terms of this Code. All employees are required to report their personal security transactions in their own and in beneficially owned securities under this Code. Additionally, Portfolio, Investment and Access Persons are required to receive preclearance of transactions and further limitations are placed on the transactions of Portfolio and Investment Persons.
Policy updated: August 21, 2019
3
Code of
1The directors or trustees of Fund Clients who are not "interested persons" (the "Independent Directors") are covered under a separate Code applicable only to them.
Policy updated: August 21, 2019
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C.Federal law requires that we have a Code of Ethics
The Investment Company Act of 1940 and the Investment Advisers Act of 1940 require that we have safeguards in place to prevent personal investment activities that might take inappropriate advantage of our fiduciary position. These safeguards are embodied in this Code of Ethics.2
Does the Code of Ethics Apply to You?
Yes! All ACI employees and contract personnel must observe the principles contained in this Code of Ethics. This Code applies to your personal investments, as well as those for which you are a beneficial owner. However, there are different requirements for different categories of employees. The category in which you have been placed generally depends on your job function, although circumstances may prompt us to place you in a different category. The range of categories is as follows:
Fewest Restrictions
Most Restrictions
Non-Access
Access
Investment
Portfolio
The standard profile for each of the categories is described below:
A.Portfolio Persons
Portfolio Persons include portfolio managers and equity investment analysts and any other Investment Persons (as defined below) with authority to enter purchase/sale orders on behalf of client portfolios.
B.Investment Persons
Investment Persons include:
•Any supervised persons that have access to nonpublic information regarding any client portfolio's securities trading, securities recommendations, or portfolio holdings or are involved in making securities recommendations that are nonpublic; and
•Any officers and directors of an investment adviser.
C.Access Persons
Access Persons are persons who, in connection with their regular function and duties, consistently obtain information regarding current purchase and sale recommendations and daily transaction and holdings information concerning client portfolios. Examples of persons that may be considered Access Persons include:
•Persons who are directly involved in the execution, clearance, and settlement of purchases and sales of securities (e.g. certain investment operations personnel);
Policy updated: August 21, 2019
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2Rule 17j-1 under the Investment Company Act of 1940 and Rule 204A-1 under the Investment Advisers Act of 1940 serve as a basis for much of what is contained in this Code of Ethics.
Policy updated: August 21, 2019
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•Persons whose function requires them to evaluate trading activity on a real-time basis (e.g. attorneys, accountants, portfolio compliance personnel);
•Persons who assist in the design, implementation, and maintenance of investment management technology systems (e.g. certain I/T personnel, including contractors);
•Support staff and supervisors of the above if they are required to obtain such information as a part of their regular function and duties; and
•An officer or "interested" director of our Fund Clients.
Single, infrequent, or inadvertent instances of access to current recommendations or real-time trading information or the opportunity to obtain such information through casual observance or bundled data security access may not be sufficient to qualify you as an Access Person.
D.Non-Access Persons
If you are an ACI officer, director, or employee and you do not fit into any of the above categories, you are a Non-Access Person. Contractors and temporary employees may be considered Non-Access Persons depending on their role. While your trading is not subject to preclearance and other restrictions applicable to Portfolio, Investment, and Access Persons, you are still subject to the remaining provisions of the Code.
Restrictions on Personal Investing Activities
A.Principles of Personal Investing
All ACI employees, officers, and directors, and members of their immediate family, must comply with the federal securities laws and other governmental rules and regulations, and maintain ACI's high ethical standards when making personal securities transactions. You must not misuse nonpublic information about client security holdings or contemplated, pending, or completed portfolio transactions for your personal benefit or the benefit of others. Likewise, you may not cause a client portfolio to take action, or fail to take action, for your personal benefit.
In addition, investment opportunities appropriate for client portfolios should not be retained for the personal benefit of yourself or others. Investment opportunities arising as a result of ACI investment management activities must first be considered for inclusion in our client portfolios.
B.Trading on Inside Information
Federal law prohibits you from trading based on material nonpublic information received from any source or communicating this information to others. This could include confidential information received by employees regarding securities that are, or maybe considered as potential portfolio investments. You are expected to abide by the highest ethical and legal standards in conducting your personal investment activities. For more information regarding what to do when you believe you are in possession of material nonpublic information, please consult ACI's Insider Trading Policy.
C.Trading in ACI Mutual Funds
Policy updated: August 21, 2019
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Excessive, short-term trading of ACI client portfolios and other abusive trading practices (such as time zone arbitrage) may disrupt portfolio management strategies and harm fund performance. These practices can
Policy updated: August 21, 2019
8
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cause funds to maintain higher-than-normal cash balances and incur increased trading costs. Short-term and other abusive trading strategies can also cause unjust dilution of shareholder value if such trading is based on information not accurately reflected in the price of the fund.
You may not engage in short-term trading or other abusive trading strategies with respect to any ACI client portfolio. For purposes of this Code, ACI client portfolios include any mutual fund, variable annuity, institutional, or other account advised or subadvised by ACI.3
Seven-Day Holding Period. You will be deemed to have engaged in short-term trading if you have purchased shares or otherwise invested in a variable-priced (non-money market) ACI client portfolio and redeem shares or otherwise withdraw assets from that portfolio within seven days. In other words, if you make an investment in an ACI client portfolio, you may not redeem shares from that fund before the completion of the seventh day following the purchase date.
Limited Trading Within 30 Days. We realize that abusive trading is not limited to a seven-day window. As a result, we may deem the sale of all or a substantial portion of an employee's purchase in an ACI client portfolio to be abusive if the sale is made within 30 days, and it happens more than once every rolling twelve months.
These trading restrictions are applicable to any account for which you have the authority to direct trades or of which you are a beneficial owner, including brokerage accounts, direct shareholder accounts, retirement plans, subadvised accounts, or accounts held through an intermediary
Transactions NOT Subject to Limitations. Automatic investments such as AMIs, dividend reinvestments, employer plan contributions, and payroll deductions are not considered transactions for purposes of the holding requirements. Redemptions in variable-priced funds that allow check writing privileges will not be considered redemptions for purposes of the holding requirements.
Information to be Provided. You may be required to provide certain information regarding mutual fund accounts beneficially owned by you and transactions in reportable mutual funds. See the Reporting Requirements for your applicable Code of Ethics classification.
D.Preclearance of Personal Securities Transactions [Portfolio, Investment, and Access Persons]
Preclearance of personal securities transactions allows ACI to prevent certain trades that may conflict with client trading activities. The nature of securities markets makes it impossible to predict all conflicts. As a consequence, even trades that are precleared can result in potential conflicts between your trades and those affected for client portfolios. You are responsible for avoiding such conflicts with any client portfolios for which you make investment recommendations. You have an obligation to ACI and its clients to avoid even a perception of a conflict of interest with respect to personal trading activities.
Policy updated: August 21, 2019
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Code of
3See Schedule A for a list of Fund Clients. See Schedule B for a list of subadvised funds.
Policy updated: August 21, 2019
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All Portfolio, Investment, and Access Persons must comply with the following preclearance procedures prior to entering into (i) the purchase or sale of a security for your own account or (ii) the purchase or sale of a security for an account for which you are a beneficial owner.4
1.Is the security a "Code-Exempt Security"?
Check Appendix 3 to see if the security is listed as a code-exempt security. If it is, then you may execute the transaction. Otherwise, proceed to the next step.
2.Preclear the transaction with Compliance by5 accessing the Code of Ethics system and entering your request at the Preclearance Request Entry screen. If you are outside of ACI's office, you may e-mail your request to CE-Code_of_Ethics@americancentury.com. You will be required to provide the following:
•Broker and account number used for the transaction;
•Issuer name;
•Security identifier (Ticker symbol, CUSIP number, etc.);
•Currency;
•Type of security (stock, bond, note, etc.);
•Number of shares; and
•Nature of transaction (purchase or sale).
3.The request will be reviewed through our preclearance process. You will receive an e-mail informing you of your approval or denial within 48 hours of entering your request.
4.If you receive preclearance for the transaction,6 you may execute the approved transaction the day your preclearance is granted and the following two (2) business days (the "Preclearance Period"). For example, if preclearance is granted at 3:00 p.m. on Wednesday, you have until the close of the market on Friday to execute the trade. If you do not execute the approved transaction within the Preclearance Period, you must repeat the preclearance procedure prior to executing the transaction.
ACI reserves the right to restrict the purchase or sale by Portfolio, Investment, and Access Persons of any security at any time. Such restrictions are imposed through the use of a Restricted List that will cause the Code of Ethics system to deny the approval of preclearance to transact in the security. Securities may be restricted for a variety of reasons including without limitation, the possession of material nonpublic information by ACI or its employees.
4See Appendix 2 for an explanation of beneficial ownership.
5If you are the Chief Investment Officer of an investment adviser, your preclearance request must be approved by the Chief
Policy updated: August 21, 2019
1
Code of
Compliance Officer or his or her designee.
6See Appendix 4 for a description of the preclearance process.
Policy updated: August 21, 2019
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E.Additional Trading Restrictions [Portfolio and Investment Persons]
The following additional trading restrictions apply if you are a Portfolio or Investment Person:
1.Initial Public Offerings You may not acquire securities issued in an initial public offering.
2.Private Placements Before you acquire any securities in a private placement, you must obtain approval. from the Chief Investment Officer. Request preclearance by entering your request in the Private Placement Preclearance Request Entry screen in the Code of Ethics system or by emailing your request to CE-Code of Ethics (or CE-Code_of_Ethics@americancentury.com if emailing from outside of ACI's email systems). While your preclearance request is pending or if you own or beneficially own the privately-placed security, you may not participate in any consideration of an investment in securities of the private placement issuer for any client portfolios
3.60-Day Rule (Short-Term Trading Profits) You may not profit from any purchase and sale, or sale and purchase, of the same (or equivalent) securities other than code-exempt securities within sixty (60) calendar days.
F.Seven-Day Blackout Period [Portfolio Persons]
If you are a Portfolio Person, you may not purchase or sell a security other than a code exempt security during the seven calendar days before and after the day it has been traded in a client portfolio that you manage (i.e., if a client portfolio transacts in a security on Monday, the Portfolio Persons managing the client portfolio must not personally trade in the security from the Monday before until the Monday after the client portfolio transaction.
G.Securities held in your funds [Portfolio Persons]
Personally investing in the same securities held by the client portfolios you manage may result in a conflict of interest. To mitigate this risk, you may not sell a security in which your client portfolio has a long position or purchase a security in which your client portfolio has a short position.
Reporting Requirements
You are required to file complete, accurate, and timely reports of all required information under this Code. All reported information is subject to review for indications of abusive trading, misappropriation of information, or failure to adhere to the requirements of this Code.
A. Reporting Requirements Applicable to All Employees
Policy updated: August 21, 2019
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1. Code Acknowledgement
Policy updated: August 21, 2019
1
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Upon employment, any amendment of the Code, and not less than annually thereafter, you will be required to acknowledge that you have received, read, and will comply with this Code. Compliance will notify you when you must provide this information.
2.Brokerage Accounts and Duplicate Confirmations
You are required to report ALL reportable brokerage accounts that you own or beneficially own in the Code of Ethics system using the Account Maintenance page or the Account Reporting page (initial and year-end reporting) as soon as the account has been established.
To aid with required recordkeeping requirements and streamline operations, employees must hold all reportable brokerage accounts at a firm that provides electronic trade confirmations to ACI. "Reportable brokerage accounts" include both brokerage accounts maintained by you and brokerage accounts maintained by a person whose trades you must report because you are a beneficial owner. See Schedule C for a list of firms that provide electronic trade confirmations to ACI. New reportable brokerage accounts must be opened with a firm that provides electronic trade confirmations to ACI.
New employees are required to move existing reportable brokerage accounts that they own or beneficially own to an electronic broker within 90 days of the start of their employment.
Limited exemptions may be granted to hold a reportable brokerage account at firms that do not provide electronic trade confirmations. You MUST contact Compliance at CE-- Code_of_Ethics@americancentury.com to obtain an account exemption.
Exemptions may be requested for Managed Accounts and Blind Trusts. Please refer to page 12 of this Code, section F. Managed Account/Blind Trust Exemption.
3.Reporting of Mutual Fund Accounts
a.Employee-owned ACI Direct Accounts/ ACI Retirement Plans
You are not required to report ACI Direct and ACI Retirement Plan accounts held under your own Social Security number. Trading in these accounts will be monitored based on information contained on our transfer agency and retirement plan systems.
b.Beneficially Owned Direct Accounts
You must report the following information for ACI Direct accounts in which you have a beneficial ownership interest held under a taxpayer identification or Social Security number other than your own (so-called "beneficially owned direct accounts"):
•Account number and
•Name(s) of record owner(s) of the account.
Trading in these accounts will be monitored based on information contained on our transfer agency
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system.
c. Certain third-party accounts invested in funds managed by ACI.
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You are required to report other accounts invested in funds managed by ACI such as those invested in (i) any subadvised fund (see Schedule B of this Code for a list of subadvised funds); and (ii) non-ACI retirement plan, unit investment trust, variable annuity, or similar accounts in which you own or beneficially own reportable mutual funds. The following information must be reported for these accounts:
•Name of the financial institution where held;
•Account number; and
•Name(s) of the record owner(s) of the account.
In addition, you must provide either account statements or confirmations of all trading activity in reportable third-party accounts to Compliance within 30 calendar days of the end of each calendar quarter.
B.Additional Reporting Requirements [Portfolio, Investment, and Access Persons]
1.Holdings Report
Within ten calendar days of becoming a Portfolio, Investment, or Access Person, and annually, thereafter, you must submit a Holdings Report. You will be notified by e-mail of the dates and requirements for filing the report(s). The information submitted must be current as of a date no more than 45 calendar days before the report is filed and include the following:
•A list of all securities, other than certain code-exempt securities 7, that you own or in which you have a beneficial ownership interest. This listing must include the financial institution, account number, security identifier and description, number of shares, currency, and principal amount of each covered security.
•A summary of your relationships that may conflict with the interests of ACI, such as outside employment, relationships with competitors, suppliers, vendors, independent contractors or consultants of ACI, or relationships with directors or trustees in outside organizations other than community charitable activities, education activities, or dissimilar family business.
•Portfolio and Investment Persons must also provide a list of all reportable mutual fund holdings owned or in which they have a beneficial ownership interest. This list must include investments held directly through ACI, investments in any subadvised fund, holdings in a reportable brokerage account, and holdings in non-ACI retirement plans, unit investment trusts, variable annuity, or similar accounts.
2.Quarterly Transactions Report
Within 30 calendar days of the end of each calendar quarter, all Portfolio, Investment, and Access Persons must submit a Quarterly Transactions Report. Compliance will notify you of the dates and requirements for filing the report. A report of the transactions for which we have received your trade confirmations during the quarter will be provided for your review. It is your responsibility to review the completeness and accuracy of this report, provide any necessary changes, and certify its contents when submitted.
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7See Appendix 3 for a listing of code-exempt securities that must be reported.
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a.The Quarterly Transactions Report must contain the following information about each personal securities transaction undertaken during the quarter other than those in certain code exempt securities:
•The financial institution's name and account number in which the transaction was executed;
•The date of the transaction, the security identifier and description and number of shares or the principal amount of each security involved;
•The nature of the transaction, that is, purchase, sale, or any other type of acquisition or disposition; and
•The transaction price, currency and amount.
In addition, information regarding your reportable brokerage and other accounts should be verified at this time.
b.Portfolio and Investment Persons are also required to report transactions in reportable mutual funds. The Quarterly Transactions Report for such persons must contain the following information about each transaction during the quarter:
•The date of the transaction, the fund identifier and description and number of shares or units of each trade involved;
•The nature of the transaction, that is, purchase, sale, or any other type of acquisition or disposition;
•The transaction price, and amount; and
•The financial institution's name and account number in which the trade was executed.
Transactions of reportable mutual funds that do not need to be reported by Portfolio and Investment Persons on the Quarterly Transaction Report include:
•Reinvested dividends;
•Transactions in ACI retirement plan accounts;
•Transactions in mutual fund accounts held directly through ACI under your Social Security number;
•Transactions in beneficially-owned Direct accounts if the account has been previously reported under this Code; and
•Transactions in reportable third-party accounts for which the account statements or confirmations are provided to Compliance within 30 days of the end of the calendar quarter in which the transactions took place.
Can there be any exceptions to the restrictions?
Yes. The Chief Compliance Officer or his or her designee may grant limited exemptions to specific provisions of the Code on a case-by-case basis.
A. How to Request an Exemption
Request an exemption by e-mailing a written request to -CE-Code of Ethics (or CE -
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Code_of_Ethics@americancentury.com if emailing from outside ACI's email system) detailing your situation.
B. Factors Considered
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In considering your request, the Chief Compliance Officer or his or her designee may grant your exemption request if he or she is satisfied that:
•Your request addresses an undue personal hardship imposed on you by the Code of Ethics;
•Your situation is not in conflict with the Code; and
•Your exemption, if granted, would be consistent with the achievement of the objectives of the Code of Ethics.
C.Exemption Reporting
All exemptions must be reported to the Boards of Directors/Trustees of our Fund Clients at the next regular meeting following the initial grant of the exemption. Subsequent grants of an exemption of a type previously reported to the Boards may be affected without reporting. The Boards of Directors/Trustees may choose to delegate the task of receiving and reviewing reports to a committee comprised of Independent Directors/Trustees.
D.Thirty-Day Denial Exemption on Sales
An exemption may be requested when a request to sell a security has been denied once a week over a 30-day timeframe. The covered person must be able to verify that they have periodically entered a preclearance request to sell a security in the Code of Ethics system at least four times over a 30-day period. A written request must be e-mailed to "CE-Code of Ethics" to request the exemption. The Chief Compliance Officer or his or her designee will review the request and determine if the exemption is warranted. If approval is granted, compliance will designate a short trading window during which the sale can take place.
E.Non-volitional Transaction Exemption
Certain non-volitional purchase and sale transactions are exempt from the preclearance requirements of the Code. These transactions include stock splits, stock dividends, exchanges and conversions, mandatory tenders, pro rata distributions to all holders of a class of securities, receipt of securities as gifts, the giving of securities, inheritances, margin/ maintenance calls (where the securities to be sold are not directed by the covered person), dividend reinvestment plans, and employer sponsored payroll deduction plans. These purchase and sale transactions, however, shall be reported in the Quarterly Transaction Report and Annual Holdings Report.
F.Blind Trust/Managed Account Exemption
An exemption from the preclearance and reporting requirements of the Code may be requested for securities that are held in a blind or quasi-blind trust arrangement or a managed (discretionary) account. For the exemption to be available, you or a member of your immediate family must not have authority to advise or direct securities transactions of the trust or managed account. A written request must be emailed to "CE-Code of Ethics" with a copy of the management agreement to request the exemption. The request will only be granted once the covered person and/or the investment adviser for the trust or managed account certify that the covered person or members of their immediate family will not advise or direct transactions. ACI may
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require that statements or trade confirmations be received for the trust or managed account. The employee and/or adviser may be requested by Compliance to re-certify the trust arrangement.
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Confidential Information
All information about clients' securities transactions and portfolio holdings is confidential. You must not disclose, except as required by the duties of your employment, actual or contemplated securities transactions, portfolio holdings, portfolio characteristics or other nonpublic information about Clients, or the contents of any written or oral communication, study, report or opinion concerning any security. Employees should consult the Portfolio Holdings and Characteristics Disclosure and the Confidential Information Asset Security policies before disseminating information to individuals that otherwise do not have access to the information. This does not apply to information which has already been publicly disclosed.
Conflicts of Interest
You must receive prior written approval from ACI's General Counsel or his or her designee, as appropriate, to do any of the following:
•Negotiate or enter into any agreement on a client's behalf with any business concern doing or seeking to do business with the client if you, or a person related to you, has a substantial interest in the business concern;
•Enter into an agreement, negotiate or otherwise do business on the client's behalf with a personal friend or a person related to you; or
•Serve on the board of directors of, or act as consultant to, any publicly traded corporation. Please note that
ACI's Business Code of Conduct also contains limitations on outside employment and directorships.
What happens if you violate the rules in the Code of Ethics?
If you violate the requirements of the Code of Ethics, you may be subject to serious penalties. Violations of the Code and proposed sanctions are documented by Compliance and submitted to the Code of Ethics Review Committee. The Committee consists of representatives of the investment adviser and the Compliance and Legal departments of ACI. The Committee is responsible for determining the materiality of Code violations and appropriate sanctions.
A.Materiality of Violation
In determining the materiality of a violation, the Committee considers:
•Evidence of violation of law;
•Indicia of fraud, neglect, or indifference to Code provisions;
•Frequency of violations;
•Monetary value of the violation in question; and
•Level of influence of the violator.
B.Penalty Factors
In assessing the appropriate penalties, the Committee will consider the foregoing in addition to any other factors they deem applicable, such as:
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•Extent of harm to client interests;
•Extent of unjust enrichment;
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•Tenure and prior record of the violator;
•The degree to which there is a personal benefit from unique knowledge obtained through employment with ACI;
•The level of accurate, honest and timely cooperation from the covered person; and
•Any mitigating circumstances.
C.The penalties which may be imposed include, but are not limited to:
1. Non-material violation
a.Warning (notice sent to manager) and/or
b.Attendance at a Code of Ethics training session and/or
c.Suspension of trading privileges.
2.Penalties for material or more frequent non-material violations will be based on the circumstances of the violation. These penalties could include, but are not limited to
a.Suspension of trading privileges and/or
b.Suspension or termination of employment.
In addition, you may be required to surrender to ACI any profit realized from any transaction(s) in violation of this Code of Ethics.
ACI's Quarterly Report to Fund Directors/Trustees
ACI will prepare a quarterly report to the Board of Directors/Trustees of each Fund Client of any material violation of this Code of Ethics.
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APPENDIX 1: DEFINITIONS
1."Automatic Investment Plan"
"Automatic investment plan" means a program in which regular periodic purchases, exchanges or redemptions are made automatically in or from investment accounts in accordance with a predetermined schedule and allocation including dividend reinvestment plans.
2."Beneficial Ownership" or "Beneficially Owned"
See "Appendix 2: What is Beneficial Ownership?"
3."Code-Exempt Security"
A "code-exempt security" is a security in which you may invest without preclearing the transaction with
ACI. The list of code-exempt securities appears in Appendix 3.
4."Federal Securities Law"
"Federal securities law" means the Securities Act of 1933, the Securities Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm- Leach-Bliley Act, any rules adopted by the Commission under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted by the Commission or the Department of Treasury.
5."Fund Clients"
Fund clients includes each Fund Client listed on Schedule A.
6."Initial Public Offering"
"Initial public offering" means an offering of securities for which a registration statement has not previously been filed with the SEC and for which there is no active public market.
7."Investment Adviser"
"Investment adviser" includes each investment adviser listed on Schedule A
8."Member of Your Immediate Family"
A "member of your immediate family" means any of the following:
•Your spouse or domestic partner;
•Your minor children; or
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•A relative who shares your home.
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For the purpose of determining whether any of the foregoing relationships exist, a legally adopted child of a person is considered a child of such person.
8."Private Placement"
"Private placement" means an offering of securities in which the issuer relies on an exemption from the registration provisions of the Federal Securities Laws, and usually involves a limited number of sophisticated investors and a restriction on resale of the securities.
9."Reportable Brokerage Accounts"
A "reportable brokerage account" includes any account in which securities are held for the direct or indirect benefit of any person subject to this Code of Ethics.
10."Reportable Mutual Fund"
A "reportable mutual fund" includes any mutual fund issued by a Fund Client (as listed on Schedule A) and any subadvised funds (as listed on Schedule B).
11."Security"
A "security" includes a large number of investment vehicles. However, for purposes of this Code of Ethics, "security"(or "securities") includes any of the following:
•Note;
•Stock, (including stock acquired in private placements and restricted stock in nonpublic companies received through an employee stock ownership program);
•Treasury stock;
•Bond;
•Debenture;
•Derivative security;
•Exchange traded funds (ETFs) or similar securities;
•Unit Investment Trusts (UIT);
•Shares of open-end mutual funds;
•Shares of closed-end mutual funds;
•Evidence of indebtedness;
•Certificate of interest or participation in any profit-sharing agreement;
•Collateral-trust certificate;
•Preorganization certificate or subscription;
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•Transferable share;
•Investment contract;
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•Voting-trust certificate;
•Certificate of deposit for a security;
•Interests in private investment companies, hedge funds, or other unregistered collective investment vehicles;
•Fractional undivided interest in oil, gas or other mineral rights;
•Any put, call, straddle, option, future, or privilege on any security or other financial instrument (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), including stock options received from an employer or through a retirement plan;
•Any put, call, straddle, option, future, or privilege entered into on a national securities exchange relating to foreign currency;
•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, future on or warrant or right to subscribe to or purchase, any of the foregoing.
12."Subadvised Fund"
A "subadvised fund" means any mutual fund or portfolio listed on Schedule B.
13."Supervised Person"
A "supervised person" means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of an investment adviser and is subject to the supervision and control of the investment adviser.
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APPENDIX 2: WHAT IS "BENEFICIAL OWNERSHIP"?
A "beneficial owner" of a security is any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise, has or shares in the opportunity, directly or indirectly, to profit or share in any profit derived from a purchase or sale of the security.
1.Are securities held by immediate family members or domestic partners "beneficially owned" by me?
Yes. As a general rule, you are regarded as the beneficial owner of securities held in the name of
•A member of your immediate family OR
•Any other person IF you obtain from such securities benefits substantially similar to those of ownership. For example, if you receive or benefit from some of the income from the securities held by your spouse, or domestic partner, you are the beneficial owner; OR
•You hold an option or other contractual rights to obtain title to the securities now or in the future.
2.Must I report accounts for which I am listed as a joint owner or have power of attorney?
Yes. As a general rule, you are regarded as an owner of any accounts for which you are listed as a joint owner or have power of attorney.
3.Am I deemed to beneficially own securities in accounts owned by a relative for whom I am listed as beneficiary upon death?
Probably not. Unless you have power of attorney to transact in such accounts or are listed as a joint owner, you likely do not beneficially own the account or securities contained in the account until ownership has been passed to you.
4.Are securities held by a company I own an interest in also "beneficially owned" by me?
Probably not. Owning the securities of a company does not mean you "beneficially own" the securities that the company itself owns. However, you will be deemed to "beneficially own" the securities owned by the company if:
•You directly or beneficially own a controlling interest in or otherwise control the company; OR
•The company is merely a medium through which you, members of your immediate family, or others in a small group invest or trade in securities and the company has no other substantial business.
5.Are securities held in trust "beneficially owned" by me?
Maybe. You are deemed to "beneficially own" securities held in trust if you or a member of your immediate family are:
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•A trustee; or
•Have a vested interest in the income or corpus of the trust; or
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•A settlor or grantor of the trust and have the power to revoke the trust without obtaining the consent of all the beneficiaries.
A blind trust exemption from the preclearance and reporting requirements of the Code may be requested if you or members or your immediate family do not have authority to advise or direct securities transactions of the trust.
6.Are securities in pension or retirement plans "beneficially owned" byme?
Maybe. Beneficial ownership does not include indirect interest by any person in portfolio securities held by a pension or retirement plan of a company whose employees generally are the beneficiaries of the plan.
However, your participation in a pension or retirement plan is considered beneficial ownership of the portfolio securities if you can withdraw and trade the securities without withdrawing from the plan or you can direct the trading of the securities within the plan (IRAs, 401(k)s, etc.).
7.Examples of Beneficial Ownership
a. Securities Held by Family Members or Domestic Partners
Example 1: Tom and Mary are married. Although Mary has an independent source of income from a family inheritance and segregates her funds from those of her husband, Mary contributes to the maintenance of the family home. Tom and Mary have engaged in joint estate planning and have the same financial adviser. Since Tom and Mary's resources are clearly significantly directed towards their common property, they shall be deemed to be the beneficial owners of each other's securities.
Example 2: Mike's adult son David lives in Mike's home. David is self-supporting and contributes to household expenses. Mike is a beneficial owner of David's securities.
Example 3: Joe's mother Margaret lives alone and is financially independent. Joe has power of attorney over his mother's estate, pays all her bills and manages her investment affairs. Joe borrows freely from Margaret without being required to pay back funds with interest, if at all. Joe takes out personal loans from Margaret's bank in Margaret's name, the interest from such loans being paid from Margaret's account. Joe is a beneficial owner of Margaret's estate.
Example 4: Bob and Nancy are in a relationship. The house they share is still in Nancy's name only. They have separate checking accounts with an informal understanding that both individuals contribute to the mortgage payments and other common expenses. Nancy is the beneficial owner of Bob's securities.
b.Securities Held by a Company
Example 5: ABC Company is a holding company with five shareholders owning equal shares in the company. Although ABC Company has no business of its own, it has several wholly-owned subsidiaries that invest in securities. Stan is a shareholder of ABC Company. Stan has a beneficial interest in the securities owned by
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ABC Company's subsidiaries.
Example 6: XYZ Company is a large manufacturing company with many shareholders. Stan is a shareholder of XYZ Company. As a part of its cash management function, XYZ Company invests in securities. Neither Stan
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nor any members of his immediate family are employed by XYZ Company. Stan does not beneficially own the securities held by XYZ Company.
c.Securities Held in Trust
Example 7: John is trustee of a trust created for his two minor children. When both of John's children reach 21, each shall receive an equal share of the corpus of the trust. John is a beneficial owner of any securities owned by the trust.
Example 8: Jane placed securities held by her in a trust for the benefit of her church. Jane can revoke the trust during her lifetime. Jane is a beneficial owner of any securities owned by the trust.
Example 9: Jim is trustee of an irrevocable trust for his 21-year-old daughter (who does not share his home). The daughter is entitled to the income of the trust until she is 25 years old, and is then entitled to the corpus. If the daughter dies before reaching 25, Jim is entitled to the corpus. Jim is a beneficial owner of any securities owned by the trust.
Example 10: Joan's father (who does not share her home) placed securities in an irrevocable trust for Joan's minor children. Neither Joan nor any member of her immediate family is the trustee of the trust. Joan is a beneficial owner of the securities owned by the trust. She may, however, be eligible for the blind trust exemption to the preclearance and reporting of the trust securities.
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APPENDIX 3: CODE-EXEMPT SECURITIES
Because they do not pose a likelihood for abuse, code-exempt securities are exempt from the Code's preclearance requirements. However, confirmations of transactions in reportable brokerage accounts are required in all cases and some code-exempt securities must also be disclosed on your Quarterly Transactions, Initial, and Annual Holdings Reports.
1.Code-Exempt Securities Not Subject toDisclosure on your Quarterly Transactions, Initial and Annual Holdings Reports:
•Open-end mutual funds that are not considered a reportable mutual fund;
•Reportable mutual funds (Access Persons only);
•Reportable mutual fund shares purchased through an automatic investment plan (including reinvested dividends);
•Money market mutual funds;
•Bank Certificates of Deposit;
•U.S. government Treasury and Government National Mortgage Association securities;
•Commercial paper;
•Bankers acceptances;
•High quality short-term debt instruments, including repurchase agreements. A "high quality short-term debt instrument" means any instrument that has a maturity at issuance of less than 366 days and that is rated in one of the two highest rating categories by a nationally recognized rating organization.
2.Code-Exempt Securities Subject toDisclosure on your Quarterly Transactions, Initial and Annual Holdings Reports:
•Reportable mutual fund shares purchased other than through an automatic investment plan (Portfolio and Investment Persons only)
•Exchange Traded Products, Closed-End Funds and Unit Investment Trusts
•Securities which are acquired through an employer-sponsored automatic payroll deduction plan (only the acquisition of the security is exempt, NOT the sale)
•Securities other than open-end mutual funds purchased through dividend reinvestment programs (only the re-investment of dividends in the security is exempt, NOT the sale or other purchases)
•Futures contracts on the following:
Standard & Poor's 500 or 100 Index, NASDAQ 100 Index, and DOW 30 Industrials futurescontracts only. Futures contracts for other financial instruments are not Code-exempt.
Commodity futures contracts for agricultural products (corn, soybeans, wheat, etc.) only. Futures contracts on precious metals or energy resources are not Code-exempt.
We may modify this list of securities at any time, please send an e-mail to "LG-Personal Security Trades" to
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request the most current list.
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APPENDIX 4: HOW THE PRECLEARANCE PROCESS WORKS
Preclearance Process
Yes
Denied
Yes
Denied
Employee reports account maintained with an electronic broker or receives
Compliance exemption for the account.
Employee enters preclearance request at http:\\coe\.
Yes
Denied
No
Yes
Is the security code-exempt?
Approved
No
If a sell request, does the
Portfolio Person's
assigned funds have a position in the security?
No
Is the trade within the
No
7-day black-out?
No
Yes
Approved
No
Have there been any open orders or fund trades for this security in the past 24 hours?
No
Is the security:
a. Owned by a fund; or
b. On the electronic follow list for any fund?
Yes
Message sent to portfolio teams asking their intent to trade the security in the next 3 days.
Approved
Approved for 2+ days preclearance.
Yes
Denied
No
Approved
Denied
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After your request is entered into our preclearance system, it is then subjected to the following tests.
Step 1: Restricted Security List
•Is the security on the Restricted Security list?
If "YES", the system will send a message to you DENYING the personal trade request.
If "NO", then your request is subject to Step 2.
Step 2: De Minimis Transaction Test
•Is the security issuer's market capitalization greater than $7.5 billion?
•Will your proposed transaction, together with your other preclearance requests in the security for the current calendar quarter, be less than $50,000?
If the answer to either of these questions is "NO", then your request is subject to Step 3.
Step 3: Client Trades Test
•Have there been any transactions in the past 24 hours or is there an open order for that security for anyClient?
If "YES", the system will send a message to you DENYING the personal trade request.
If "NO", then your request is subject to Step 4.
Step 4: Follow List Test
•Does any account or Fund own the security?
•Does the security appear on the computerized list of stocks ACI is considering to purchase for a Client?
If the answer to BOTH of these questions is "NO", the system will send a message to you APPROVING your proposed transaction.
If the answer to EITHER of these questions is "YES", then your request is subject to Step 5.
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Step 5: Present Intentions Test
A message is sent to portfolio teams that own or are following the security described in your preclearance request. The portfolio teams will be asked if they intend to buy or sell the security within the next three (3) business days.
If ALL of the portfolio management teams respond "NO", your request will be APPROVED. If
ANY of the portfolio management teams respond "YES", your request will be DENIED.
If ANY of the portfolio teams do not respond, your request will be DENIED.
The preclearance process can be changed at any time to ensure that the goals of this Code of Ethics are met.
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SCHEDULE A: BOARD APPROVAL DATES
This Code of Ethics was most recently approved by the Board of Directors/Trustees of the following Companies as of the dates indicated:
Investment Adviser
Most Recent Approval Date
American Century Investment Management, Inc.
January 1, 2018
Principal Underwriter
Most Recent Approval Date
American Century Investment Services, Inc.
January 1, 2018
Fund Clients
Most Recent Approval Date
American Century Asset Allocation Portfolios, Inc.
December 1, 2017
American Century California Tax-Free and Municipal Funds
December 14, 2017
American Century Capital Portfolios, Inc.
December 1, 2017
American Century Government Income Trust
December 14, 2017
American Century Growth Funds, Inc.
December 1, 2017
American Century International Bond Funds
December 14, 2017
American Century Investment Trust
December 14, 2017
American Century Municipal Trust
December 14, 2017
American Century Mutual Funds, Inc.
December 1, 2017
American Century Quantitative Equity Funds, Inc.
December 14, 2017
American Century Strategic Asset Allocations, Inc.
December 1, 2017
American Century Target Maturities Trust
December 14, 2017
American Century Variable Portfolios, Inc.
December 1, 2017
American Century Variable Portfolios II, Inc.
December 14, 2017
American Century World Mutual Funds, Inc.
December 1, 2017
American Century ETF Trust
December 20, 2017
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SCHEDULE B: SUBADVISED FUNDS
This Code of Ethics applies to the following funds which are subadvised by an investment adviser. This list of affiliated funds will be updated on a regular basis.
CIBC Balanced Fund
CIBC Global Equity Growth Pool
CIBC Global Monthly Income Fund
CIBC International Equity Fund
CIBC International Small Companies Fund
CIBC Monthly Income Fund
CIBC U.S. Equity Value Pool
Columbia Funds Variable Series Trust II: CTIVP-American Century Diversified Bond Fund
EQ Advisors Trust: EQ/American Century Mid Cap Value Portfolio
EQ Advisors Trust Multimanager Mid Cap Value Portfolio
GuideStone Funds: Defensive Market Strategies Fund
GuideStone Funds: Value Equity Fund
Imperial International Equity Pool
Imperial Overseas Equity Pool
Learning Quest 529 Education Savings Program
Lincoln Variable Insurance Products Trust LVIP American Century Select Mid Cap Managed Volatility Fund
MassMutual Select Funds: MassMutual Select Mid-Cap Value Fund
MassMutual Select Funds: MassMutual Select Small Company Value Fund
Mercer Funds: Mercer Non-U.S. Core Equity Fund
Mercer Global Investments Canada Limited: Mercer International Equity Fund
MML Series Investment Fund: MML Mid Cap Value Fund
Nationwide Variable Insurance Trust: American Century NVIT Multi Cap Value Fund
Nationwide Variable Insurance Trust: NVIT Multi-Manager Mid Cap Value Fund
Nomura ACI Advanced Medical Impact Investment Mother Fund
Nomura ACI Global REIT Mother Fund
Nomura Institutional Fund Select American Century Global Growth Fund
Nomura U.S. Municipal General Obligation Bond Mother Fund
Nomura U.S. Value Strategy Mother Fund
Nomura Currency Fund U.S. Growth Equity Fund
Northwestern Mutual Series Fund, Inc.: Inflation Protection Portfolio
Northwestern Mutual Series Fund, Inc.: Large Company Value Portfolio
Schedule B updated: July 1, 2019
Schedule C updated: March 29, 2019
Policy updated: August 21, 2019
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Code of
Northwestern Mutual Series Fund, Inc.: Mid Cap Value Portfolio
Schedule B updated: July 1, 2019
Schedule C updated: March 29, 2019
Policy updated: August 21, 2019
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Code of
Penn Series Funds, Inc.: Mid Core Value Fund
PrivilEdge American Century Emerging Markets Equity
Renaissance Canadian Balanced Fund
Renaissance Canadian Monthly Income Fund
Renaissance Global Focus Fund
Renaissance International Equity Private Pool
Renaissance Private Pools Renaissance Global Equity Private Pool
Renaissance U.S. Equity Income Fund
Schwab Capital Trust: Laudus International MarketMasters Fund
Seasons Series Trust: SA Multi-Managed Large Cap Value Portfolio
VALIC Company I: Growth Fund
Voya Partners, Inc.: VY American Century Small-Mid Cap Value Portfolio
Schedule B updated: July 1, 2019
Schedule C updated: March 29, 2019
Policy updated: August 21, 2019
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Code of
SCHEDULE C: APPROVED ELECTRONIC BROKERS
The following brokers have entered into an agreement with ACI to provide trade confirmations electronically. Employees are prohibited from holding accounts at firms that do not provide electronic trade confirmations unless an account exemption has been given. Please send a message LG-personal_security_trades@americancentury.com to request an account exemption.
American Century Brokerage
American Century Personal Financial Solutions (held at Pershing)
Ameriprise
Charles Schwab
Edward Jones
ETRADE
Fidelity
Interactive Broker
JP Morgan Private Bank
Merrill Lynch
Morgan Stanley
Northern Trust
Northwestern Mutual
Raymond James
RBC
TD Ameritrade
UBS
USAA Brokerage
Vanguard
Wells Fargo
Schedule B updated: July 1, 2019
Schedule C updated: March 29, 2019
Policy updated: August 21, 2019
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Code of Ethics
Policy Original Effective Date: January 2, 2018
Policy Revision Date: December 5, 2019
Version 3.0
Appendicies |
|
Appendix A Proprietary Fund List ................................................................................. |
21 |
Appendix B Approved Brokers List ............................................................................... |
23 |
Appendix C Initial/Annual Employee Certification ....................................................... |
24 |
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I.Introduction and Background
(Definitions of Terms not otherwise defined can be found in Section II.)
This Code of Ethics (the "Code") has been adopted by CenterSquare Investment
Management LLC, and its subsidiary entity, RCG Longview Management LLC, each of which are registered investment advisers under the Investment Advisers Act of 1940, as amended (the "Advisers Act"), and collectively referred to herein as, the "Company", the "Adviser", the "Firm", or "CenterSquare", primarily for the purpose of providing rules for Supervised Persons with respect to adherence to certain standards of conduct along with abiding by policies regarding personal securities transactions.
Securities and Exchange Commission (the "SEC") Rule 204A-1 (the "Rule") under the
Advisers Act, as amended, requires investment advisers to adopt a code of ethics. The Rule requires an investment adviser's code of ethics to set forth standards of conduct and requires Supervised Persons to comply with applicable federal securities laws. The code of ethics must address personal trading, including the reporting of personal securities holdings and transactions and the pre-approval of certain transactions and investments. This Code was adopted to adhere to the Rule. As a sub-adviser to one or more Investment Companies registered under the Investment Company Act of 1940, as amended (the "1940 Act"), the
Code also adheres to Rule 17j-1 under the 1940 Act.
The Code applies to all Supervised Persons of the Company. In addition, the Rule requires any Supervised Person that is also an Access Person of the Adviser to report, and the investment adviser to review, their personal securities transactions and holdings periodically. Refer to Section III for personal security trading policies.
Importance of Compliance
CenterSquare provides investment advisory services for its clients' investments in private equity and debt real estate investments and publicly traded real estate securities and publicly traded infrastructure securities. CenterSquare's clients are primarily institutional pension plans. Investment vehicles advised or subadvised by CenterSquare include separate accounts, private commingled equity and debt real estate funds, other pooled investment vehicles including foreign funds and subadvised bank collective funds. Additionally, CenterSquare is a subadviser to multiple Investment Companies.
CenterSquare has a fiduciary duty to each and every one of its clients. The policy of CenterSquare is to treat its clients fairly and equitably, including to protect the interests of each of its clients and to place a client's interests first and foremost in each and every situation. The Adviser's fiduciary duty includes providing to clients and potential clients full and fair disclosure of all relevant facts and any potential or actual conflicts of interest. Each Supervised Person has a responsibility to act in a manner consistent with this duty.
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Every Supervised Person must focus on the interests of the clients first and bring to the attention of CenterSquare's Compliance Team ("Compliance") any matter that appears to them to compromise the interest of any client. The email address to reach the Compliance Team is compliance@centersquare.com . It is the responsibility of all Supervised Persons to understand fully and comply with the Code and the policies of CenterSquare and to seek guidance whenever necessary.
Regulatory Background
The investment management industry is closely regulated under the provisions of the federal securities laws including, but not limited to, the Advisers Act and the 1940 Act, and by the regulations and interpretations of the SEC under those statutes. Transactions in securities are also governed by the provisions of the Securities Act of 1933, as amended (the "Securities Act"), and the Securities Exchange Act of 1934, as amended (the "Exchange Act") as well as by state laws. The rules of conduct set forth in this Code are based in large part on rules of law and legal concepts developed under the federal securities laws. These legal concepts do not remain static, and further developments of the law in these areas may be expected. They were developed in an effort to self-regulate and preserve investors' confidence that their interests are placed ahead of our own personal trading activities. Supervised Persons of the Company should conduct business to avoid not only any violation of law, but also any appearance of violation or grounds for criticism.
Compliance shall provide this Code, as well as any amendments, to each Supervised Person, and each Supervised Person shall be required to provide written acknowledgement of receipt thereof and also confirm its understanding of its contents on no less than an annual basis.
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II.Definitions
The following represent terms and related definitions that are used in this Code. Access Persons
An Access Person means any Supervised Person of the Company who (1) has access to non-public information regarding any clients' purchase or sale of securities, or non- public information regarding the portfolio holdings of any Proprietary Fund, or (2) is involved in making securities recommendations to clients, or who has access to such recommendations that are non-public. All Employees of CenterSquare are designated as an Access Person. The CCO may designate other non-employee Supervised Persons as Access Persons.
Automatic Investment Plan
A program in which regular periodic purchases (withdrawals) are made automatically to/from investment accounts in accordance with a predetermined schedule and allocation. Examples include: Dividend Reinvestment Plans (DRIPS), payroll deductions, bank account drafts or deposits, automatic mutual fund investments/withdrawals (PIPS/SWIPS), and asset allocation accounts.
Covered Securities
Covered Securities means any security as defined in section 2(a)(36) of the 1940 Act, except:
(i)Direct obligations of the Government of the United States;
(ii)Bankers' acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements; and
(iii)Shares issued by Investment Companies
Direct Ownership
Direct ownership means Employee is named on the security or account.
Employee
An individual employed by CenterSquare. This includes all full-time and part-time employees in all CenterSquare locations.
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Exempt Securities
All securities require reporting unless expressly exempt by this policy. The below securities are exempt from reporting.
∙Cash and cash-like securities (e.g., bankers acceptances, bank CDs and time deposits, money market funds, commercial paper, repurchase agreements);
∙Direct obligations of the United States;
∙High-quality, short-term debt instruments having a maturity of less than 366 days at issuance and rated in one of the two highest rating categories by a nationally recognized statistical rating organization or which is unrated but of comparable quality;
∙Securities issued by open-end investment companies (i.e., mutual funds, variable capital companies, and Index Funds) that are not exchange traded funds and not a Proprietary Fund;
∙Securities in non-Company 401(k) plans (e.g., spouse's plan, previous employer's plan, etc.) unless the non-Company 401(k) plan contains a self- directed account in which reportable securities can be traded;
∙Securities in qualified tuition programs ("529 Plans"), except to the extent the qualified tuition programs hold Proprietary Funds;
∙Fixed annuities;
∙Variable annuities that invest in funds which are not Proprietary Funds;
∙Securities held in approved non-discretionary Managed Accounts (i.e., the Employee has given total investment discretion to an investment manager and retains no ability to influence specific trades); and
∙Stock held in a bona fide Employee benefit plan of an organization not affiliated with CenterSquare on behalf of an employee of that organization, who is a member of CenterSquare Employee's immediate family. For example, if an Employee's spouse works for an organization unrelated to CenterSquare, the Employee is not required to report for transactions that his/her spouse makes in the unrelated organization's company stock so long as they are part of an employee benefit plan. This exemption does not apply to any plan that allows the Employee to buy and sell securities other than those of their employer. Such situations would subject the account to all requirements of this policy.
Exchange Traded Fund ("ETF")
A type of exchange-traded investment product that must register with the SEC under the 1940 Act as either an open-end investment company or a unit investment trust. Like mutual funds, ETFs offer investors a way to pool their money in a fund that makes investments in stocks, bonds, or other assets and, in return, to receive an interest in that investment pool. Unlike mutual funds, however, ETF shares are traded on a national stock exchange and at market prices that may or may not be the same as the net asset value ("NAV") of shares, that is, the value of the ETF's assets, minus its liabilities divided by the number of shares outstanding.
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Front Running
The purchase or sale of securities for an Employee's own, or the company's, accounts on the basis of Employee's knowledge of the company's or company's clients trading positions or plans.
Index Fund
An Investment Company or managed portfolio (including indexed accounts and model- driven accounts) that contain securities in proportions designed to replicate the performance of an independently maintained, broad-based index or that is based not on investment discretion but on computer models using prescribed objective criteria to replicate such an independently maintained index.
Indirect Ownership
Generally, an Employee is the indirect owner of securities if the Employee is named as power of attorney on the account or, through any contract, arrangement, understanding, relationship, or otherwise, the Employee has the opportunity, directly or indirectly, to share at any time in any profit derived from a transaction in them (a "pecuniary interest"). Common indirect ownership situations include, but are not limited to:
∙Securities held by members of an Employee's immediate family by blood, marriage, adoption, or otherwise, who share the same household with the Employee.
∙"Immediate family" includes an Employee's spouse, domestic partner, children (including stepchildren, foster children, sons-in-law and daughters- in-law), grandchildren, parents (including step-parents, mothers-in-law and fathers-in-law), grandparents, and siblings (including brothers-in-law, sisters-in-law and stepbrothers and stepsisters).
∙Partnership interests in a general partnership or a general partner in a limited partnership. Passive limited partners are not deemed to be owners of partnership securities absent unusual circumstances, such as influence over investment decisions.
∙Corporate shareholders who have or share investment control over a corporation's investment portfolio.
∙Trusts in which the parties to the trust have both a pecuniary interest and investment control.
∙Derivative securities An Employee is the indirect owner of any security for which the Employee has the right to acquire through the exercise or conversion of any option, warrant, convertible security or other derivative security, whether or not presently exercisable.
∙Securities held in investment clubs.
Initial Public Offering ("IPO")
The first offering of a company's securities to the public.
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Investment Clubs
Organizations whose members make joint decisions on which securities to buy or sell. The securities are generally held in the name of the investment club. Prior to participating in an investment club, all Employees are required to obtain written permission from the CCO. Employees who receive permission to participate in an investment club are subject to the requirements of this policy.
Investment Company
A company that is registered under the 1940 Act as an open-end investment company, a closed-end investment company or unit investment trust and that issues securities that represents an undivided interest in the net assets held by the company. Mutual funds, including Money Market Funds, are open-end investment companies that issue and sell redeemable securities representing an undivided interest in the net assets of the company.
Money Market Fund
An Investment Company that invests in short-term debt instruments where its portfolio is valued at amortized cost so as to seek to maintain a stable net asset value (typically, of $1 per share).
Managed Account
An account in which the Employee has a beneficial interest but no direct or indirect control over the investment decision-making process. It may be exempted from preclearance and reporting procedures only if the CCO is satisfied that the account is truly non-discretionary (i.e., the Employee has given total investment discretion to an investment manager and retains no ability to influence specific trades).
Option
A security which gives the investor the right, but not the obligation, to buy or sell a specific security at a specified price within a specified timeframe. For purposes of compliance with this policy, an Employee who buys/sells an option is deemed to have purchased/sold the underlying security when the option was purchased/sold. Four combinations are possible as follows:
Call Options
∙If an Employee buys a call option, the Employee is considered to have purchased the underlying security on the date the option was purchased.
∙If an Employee sells a call option, the Employee is considered to have sold the underlying security on the date the option was sold (for covered call writing, the sale of an out-of-the-money option is not considered for purposes of the 60 day trading prohibition).
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Put Options
∙If an Employee buys a put option, the Employee is considered to have sold the underlying security on the date the option was purchased.
∙If an Employee sells a put option, the Employee is considered to have bought the underlying security on the date the option was sold.
Personal Trading Accounts
Personal Trading Accounts include discretionary accounts with Direct or Indirect Ownership and includes accounts that have the capability of holding Reportable Securities, whether or not the account currently holds Reportable Securities.
Personal Trading Restricted Securities List
Access Persons are prohibited from holding securities in discretionary accounts that are part of CenterSquare's universe of investable public securities. Securities that are held, or may be held, by client accounts are reported in this list and serves to prohibit Access Persons from preclearance of restricted securities.
Private Placement
An offering of securities that is exempt from registration under various laws and rules, such as the Securities Act in the United States and the Listing Rules in the United Kingdom. Such offerings are exempt from registration because they do not constitute a public offering. Private placements can include limited partnerships, certain cooperative investments in real estate, commingled investment vehicles such as hedge funds, and investments in privately held and family-owned businesses. For the purpose of this policy, time-shares and cooperative investments in real estate used as a primary or secondary residence are not considered to be private placements.
Proprietary Fund(s)
An Investment Company or commingled fund for which CenterSquare serves as a sub- adviser. Refer to Appendix A for a list of Proprietary Funds.
Reportable Securities
Any security, including Covered Securities, unless expressly exempt (see definition of Exempt Securities). Securities include any investment that represents an ownership stake or debt stake in a company, partnership, governmental unit, business or other enterprise. It includes stocks, bonds, notes, evidences of indebtedness, certificates of participation in any profit-sharing agreement, units in collective investment undertakings, collateral trust certificates and certificates of deposit. It also includes security-based derivatives and swaps and many types of puts, calls, straddles and Options on any security or group of securities; fractional undivided interests in oil, gas, or other mineral rights; and investment contracts, variable life insurance policies and variable annuities whose cash values or benefits are tied to the performance of an investment account. Reportable securities also include Proprietary Funds and Exchange Traded Funds.
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Scalping
The purchase or sale of securities for clients for the purpose of affecting the value of a security owned or to be acquired by the Employee or the company.
Self-Directed Accounts
An account established as part of CenterSquare's 401(k) plan or non-Company 401(k) plan that offers Employees or an Employee's immediate family member the opportunity to build and manage their own investment portfolio through the purchase and sale of a broad variety of Investment Company Funds including Exchange Traded Funds, Index Funds, Proprietary Funds, non-Proprietary Funds, and other reportable securities.
Short Sell
The sale of a security that is not owned by the seller at the time of the trade.
Spread Betting
A type of speculation that involves taking a bet on the price movement of a security. A spread betting company quotes two prices, the bid and offer price (also, called the spread), and investors bet whether the price of the underlying security will be lower than the bid or higher than the offer. The investor does not own the underlying security in spread betting, they simply speculate on the price movement of the stock.
Supervised Person(s)
Supervised Persons is defined as any officer or director (or other person occupying a similar status or performing similar functions), or Employee, or other person who provides investment advice on behalf of CenterSquare and is subject to the supervision and control of CenterSquare.
The CenterSquare Compliance Monitored List
The CenterSquare Compliance Monitored List is a list of publicly traded companies that are restricted by CenterSquare Compliance for client trading for various reasons. Such reasons may include, but are not limited to, a company about which CenterSquare personnel have acquired material non-public information ("MNPI") or a position where CenterSquare may have a securities filing obligation.
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III.Personal Securities Trading Policies
A. Introduction/Purpose
The Adviser's Access Persons are subject to certain laws and/or regulations governing the personal trading of securities/financial instruments (collectively referred to as "securities" throughout this policy) including the securities laws of various jurisdictions pursuant to Rule 204A-1 under the Advisers Act, and Rule 17j-1 under the 1940 Act. In order to ensure that all Access Persons' personal investments are free from conflicts of interest and are in full compliance with the laws and regulations of all jurisdictions in which the Adviser does business, the Adviser has established limitations on personal trading. This section describes the requirements and restrictions related to personal securities transactions.
B. Applicability and Scope
Each Access Person as designated by the CCO agrees to be bound by these personal securities trading policies.
C.Policy Details/Discussion
a)Compliance with this Policy
Employees must read and understand this policy and comply with the spirit and the strict letter of its provisions. Failure to comply may result in the imposition of serious sanctions, which may include, but are not limited to, the disgorgement of profits, cancellation of trades, selling of positions, suspension of personal trading privileges, dismissal, and referral to law enforcement or regulatory agencies.
The provisions of the policy have worldwide applicability and cover trading in any part of the world, subject to the provisions of any controlling local law. To the extent any particular portion of the policy is inconsistent with, or in particular less restrictive than such laws, Employees must consult with Compliance.
To report a known or suspected violation of this policy, immediately contact Compliance.
b)CenterSquare Personal Trading Restricted Securities List
As a risk mitigant, Access Persons are prohibited from holding securities in discretionary accounts that are part of CenterSquare's universe of investable public securities. Securities that are held, or may be held, by client accounts are reported in CenterSquare's Personal Trading Restricted Securities List and serves to prohibit
Access Persons from preclearance of restricted securities. Any exceptions to this requirement is subject to written approval by the CCO.
c)General Requirements
The following general requirements apply to all Employees of the Company. In addition to the below standards of conduct, Access Persons must also comply with the additional requirements as described in the next section of this policy (See Additional Requirements).
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a)Fiduciary Duty
The Company and its Employees may owe a fiduciary duty to every client. Among the duties that an Employee owes a client when acting as a fiduciary on their behalf is not to engage in personal securities transactions that may be deemed to take inappropriate advantage of his/her position in relation to that client. Employees must be mindful of this obligation, use their best efforts to honor it, and report promptly to Compliance any Company Employee that fails to meet this obligation.
b)Protecting Material Non-public Information and Compliance with Securities Laws
Employees, in carrying out job their responsibilities, must, at a minimum, comply with all applicable legal requirements and securities laws. Employees may receive information about the Company, its clients, or other parties that for various reasons must be treated as confidential. With respect to these parties, Employees are not permitted to divulge to anyone (except as may be permitted in accordance with approved procedures) current portfolio positions (different rules will determine what is deemed to be "current"), current or anticipated portfolio transactions, or programs or studies of the Company or any client. Employees must comply with measures in place to preserve the confidentiality of information.
c)Prohibitions Against Insider Trading
Employees and the members of their household are prohibited from engaging in, or helping others engage in, insider trading. Generally, the "insider trading" doctrine under U.S. federal securities laws prohibits any person (including investment advisers) from knowingly or recklessly breaching a duty owed by that person by:
∙trading while in possession of material, non-public information;
∙communicating ("tipping") such information to others;
∙recommending the purchase or sale of securities on the basis of such information; or
∙providing substantial assistance to someone who is engaged in any of the above activities.
This means that Employees and members of their household may not trade with respect to a particular security or issuer at a time when that person knows or should know that he or she is in possession of material non-public information about the issuer or security. Information is considered "material" if there is a substantial likelihood that a reasonable investor would consider it important in making his or her investment decisions, or if it could reasonably be expected to affect the price of a company's securities.
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Material information can also relate to events or circumstances affecting the market for a company's securities such as information about an expected government ruling or regulation that can affect the business of a company in which a client may invest. Information is considered non-public until such time as it has been disseminated in a manner making it available to investors generally (e.g., through national business and financial news wire services).
Unlawful disclosure/Tipping laws may apply to any person who passes along MNPI upon which a trade or order is based. Employees who possess MNPI about an issuer of securities (whether that issuer is the Company, another company, a client or supplier, any fund or other issuer) must not trade in that issuer's securities, either for their own accounts or for any account over which they exercise investment discretion.
Employees who possess MNPI about an issuer of securities must not induce another person to engage in insider trading or trade where the person using the recommendation or inducement knows or ought to know that it is based upon MNPI.
Refer to the Company's Securities Firewalls Policy for guidance in determining when information is material and/or nonpublic and how to handle such information.
d)Trading in Securities
Employees must be sensitive to any impropriety in connection with their personal securities transactions in securities of any issuer, including those owned indirectly (see Indirect Ownership in Section II of this Code, Definitions). In addition, Employees are prohibited from Front Running and Scalping.
e)Spread Betting
Taking bets on securities pricing to reflect market movements activities as a mechanism for avoiding the preclearance restrictions on personal securities trading arising under the provisions of this policy is prohibited. Such transactions themselves constitute transactions in securities for the purposes of the policy and are subject to all of the provisions applicable to other non- exempted transactions.
f)Initial Public Offerings
Employees are prohibited from acquiring securities in a Personal Trading Account through an allocation by the underwriter of an initial public offering (IPO). Any questions as to whether a particular offering constitutes an IPO, should be directed to Compliance before submitting an indication of interest to purchase the security.
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g)Private Placements
∙Acquisition Employees are prohibited from acquiring any security in a Private Placement unless the Employee obtains prior written approval from Compliance. In order to receive approval, Employees must complete and submit to Compliance the Private Placement Form, which can be found in BasisCode or by sending an email to Compliance.
∙Subsequent Actions Subsequent subscriptions to the same private placement do not require preclearance unless they are material in size. If an Employee is unsure whether an additional subscription requires preclearance, please consult with Compliance.
∙Company Sponsored Investments No pre-clearance is required for investments in Company (or affiliate) sponsored or Company managed private placements. Employees will periodically confirm such investments when requested by Compliance.
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D. Additional Requirements
In addition to the General Requirements described above, Access Persons are also subject to the following requirements:
1.Monitored Personal Trading Activity
In order to ensure compliance with securities laws and to avoid even the appearance of a conflict of interest, Compliance monitors the personal trading activities of Access Persons, that maintain Personal Trading Accounts, via an automated personal securities trading system called BasisCode. Personal Trading Accounts include discretionary accounts with Direct or Indirect Ownership and includes accounts that have the capability of holding Reportable Securities, whether or not the account currently holds Reportable Securities. Compliance will grant Access Persons secure access to the system so that they can fulfill their personal securities trading reporting requirements as described below.
2.Exceptions to Reporting Requirements No Access Person is required to submit:
(i)any report with respect to covered securities held in a personal account over which the employee "had no direct or indirect influence or control" (e.g., a blind trust). Recent SEC staff guidance addressing such accounts states that the SEC staff believes that the fact that an employee provides a trustee with management authority over a trust for which he or she is grantor or beneficiary, or provides a third-party manager discretionary investment authority over his or her personal account, by itself, is insufficient for an adviser to reasonably believe that the employee had no direct or indirect influence or control over the trust or account for purposes of relying on the reporting exception; or
(ii)a transaction report with respect to transactions effected pursuant to an Automatic Investment Plan (i.e., a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation, including any dividend reinvestment plans).
3.Managed Accounts
Access Persons may open and maintain Managed Accounts with any broker including non-approved brokers. The requirements listed under this Additional Requirements section do not apply to Managed Accounts. Generally, a Managed Account is an account in which the Employee has a beneficial interest but no direct or indirect control over the investment decision making process. It may be exempted from preclearance and reporting procedures only if Compliance is satisfied that the account is truly non- discretionary (i.e., the Employee has given total investment discretion to an investment manager and retains no ability to influence specific trades).
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Access Persons are required to submit their discretionary investment management agreement, their Managed Account broker name and account numbers, and if deemed necessary by Compliance, the Access Persons and broker must provide an attestation that the account is truly discretionary. Access Persons are also required to complete an annual certification regarding Managed Accounts. Managed Accounts must also be disclosed by the employee in BasisCode. In addition, Access Persons are required to provide copies of statements to Compliance when requested.
4.Personal Securities Trading Reporting
a) Initial and Annual Reporting (Holdings Reports and Attestation)
Within ten days after a person is classified by Compliance as an Access Person, and annually thereafter, such person shall submit to Compliance a completed Initial Holdings Report. The report is completed within the personal securities trading system, BasisCode. Each holdings report must contain, at a minimum, (a) the title and type of Security, and as applicable, the exchange ticker symbol or CUSIP number and number of shares of each Reportable Security in which the person has any direct or indirect beneficial ownership; (b) the name of any broker, dealer or bank with whom the person maintains an account in which any Covered Securities are held for the person's direct or indirect benefit; and (c) the date the person submits the report. The Initial Holdings Report, which includes an initial broker account template and required for current broker statements, must be current as of a date no more than 45 days prior to the date the person is classified as an Access Person. The Annual Holdings Report, which is included in the fourth quarter personal trading certification, shall be submitted prior to 30 days after the end of the most recent completed calendar year end and must reflect actual holdings as of the end of the most recent completed calendar year. All Access Persons must also complete an Initial and Annual Attestation statement (see the Initial/Annual Employee Certification form included as Appendix C).
b) Quarterly Reporting (Transaction Reports)
Each Access Person shall complete quarterly transaction reporting by completing certifications in BasisCode showing all transactions in Reportable Securities in which the person has, or by reason of such transaction acquires, any direct or indirect beneficial ownership, as well as all accounts established with brokers, dealers or banks during the calendar quarter in which any Reportable Securities were held for the direct or indirect beneficial interest of the Access Person. Such reports shall be filed no later than 30 days after the end of each calendar quarter.
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5.Updating the Company's Personal Trading System
a) New Accounts
Access Persons are responsible for adding to the Company's personal securities trading system as soon as possible any new Personal Trading Accounts that are opened after the Initial Holdings Report has been submitted. This requirement applies to both Direct and Indirect Ownership Personal Trading Accounts.
b) Gifts and Inheritances
Access Persons who give or receive a gift of Reportable Securities (excluding Exempt Securities) or receive an inheritance that includes Reportable Securities (excluding Exempt Securities) must report the activity in the Company's personal securities trading system within 10 calendar days. The report must disclose the name of the person receiving or giving the gift or inheritance, date of the transaction, and name of the broker through which the transaction was effected (if applicable). A gift of Reportable Securities must be one where the donor does not receive anything of monetary value in return.
6.Approved Broker-Dealers
All U.S.-based Access Persons must maintain any Direct or Indirect Ownership Personal Trading Accounts that may hold Reportable Securities at specific broker- dealers that have been approved by the Company. These approved broker-dealers will provide electronic feeds that will automatically update Reportable Securities. Refer to Appendix B for a list of Company Approved Brokers. Access Persons living outside the U.S. are not subject to this requirement, and accordingly are required to upload quarterly broker statements into BasisCode. Annual broker statements are considered acceptable for Personal Trading Accounts which only hold or are established to hold one security (i.e. single security holdings in Computershare account). Any other exceptions to this requirement must be approved, in writing, by the CCO.
7.Account Statements
U.S.-based Access Persons who receive an exception to the approved broker-dealer requirement or who are in the process of moving their Personal Trading Account(s) to an approved broker-dealer must either submit quarterly statements directly to Compliance or upload them to BasisCode. Non-U.S.-based Access Persons are required to submit their quarterly account statements (unless another frequency is approved by the CCO) to Compliance or upload them to BasisCode. This requirement applies to both Direct and Indirect Ownership accounts and includes any account that has the capability of holding Reportable Securities (excluding Exempt Securities) regardless of what the account is currently holding.
For Reportable Securities held outside of a Personal Trading Account (such as those held directly with an issuer or maintained in paper certificate form), Access Persons must comply with the Company's request to confirm such transactions and holdings, which is generally performed annually.
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8.Proprietary Funds
Access Persons are required to report (and preclear transactions) in the personal securities trading system any Proprietary Funds held in brokerage accounts or held directly with the mutual fund company. Refer to Appendix A for a list of Proprietary Funds.
Proprietary Funds may also be available to Access Persons within CenterSquare's company 401(k) plan. Please note the following when investing in Proprietary Funds within the Company's 401(k):
∙Regular contributions via elections are NOT considered purchases, and therefore, do not require preclearance;
∙Rebalancing into or out of a Proprietary Fund IS considered a purchase or sale. Preclearance is required when rebalancing into or out of Proprietary Funds; and
∙Since CenterSquare's 401(k) is not linked to the personal securities trading system, transaction activity of Proprietary Funds is manually updated by Compliance on a quarterly basis. No action is required by the Access Person outside of preclearing purchases and sales as detailed above.
9.Preclearing Trades in the Personal Securities Trading System
Access Persons are required to receive preclearance approval in the Company's personal securities trading system prior to executing trades in all Reportable Securities (excluding Exempt Securities). Access Persons must also preclear trades in Proprietary Funds. See below for more details regarding trade preclearance requirements.
Trade Preclearance Requirements:
Access Persons are required to preclear trades as noted above. General Preclearance Requirements:
a)Obtain Preclearance Prior to Initiating a Transaction
In order to trade Reportable Securities, Access Persons are required to submit a preclearance request in the Company's personal securities trading system and receive notice that the preclearance request was approved prior to placing a security trade. Unless expressly exempt (see exemptions below), all securities transactions are covered by this preclearance requirement. Although preclearance approval does not obligate an Employee to place a trade, preclearance should not be made for transactions the Employee does not intend to make. Employees may not discuss the response to a preclearance request with anyone (excluding any account co-owners or indirect owners).
b)Execute Trade Within Preclearance Window (Preclearance Expiration)
Preclearance authorization will expire at the end of the second business day after it is received. The day authorization is granted is considered the first business day. See example below.
18
Example:
An Access Person requests and receives trade preclearance approval on Monday at 3 PM EST. The preclearance authorization is valid until the close of business on Tuesday.
Note of Caution:
Employees who place "limit," "stop-loss," "good-until-cancelled," or "standing buy/sell" orders are cautioned that transactions receiving preclearance authorization must be executed before the preclearance expires. At the end of the preclearance authorization period, any unexecuted order must be canceled. A new preclearance authorization may be requested; however, if the request is denied, the trade order with the broker-dealer must be canceled immediately.
c)Exemptions from the Requirement to Preclear
Preclearance is not required for the following security transactions:
∙Exempt Securities as defined in the Definitions in Section II of this Code.
∙Non-financial commodities (e.g., agricultural futures, metals, oil, gas, etc.), currency, and financial futures (excluding stock and narrow-based stock index futures).
∙Involuntary on the part of an Employee (such as stock dividends or sales of fractional shares); however, sales initiated by brokers to satisfy margin calls are not considered involuntary and must be precleared.
∙Pursuant to the exercise of rights (purchases or sales) issued by an issuer pro rata to all holders of a class of securities, to the extent such rights were acquired from such issuer.
∙Sells effected pursuant to a bona fide tender offer.
∙Pursuant to an Automatic Investment Plan.
∙Cryptocurrency
10.Profit Disgorgement on Short-Term Trading
Any profits recognized from purchasing then selling or selling then purchasing the same or equivalent (derivative) Reportable Securities within any 60 calendar day period must be disgorged. For purposes of disgorgement, profit recognition is based upon the difference between the most recent purchase and sale prices for the most recent transactions. Accordingly, profit recognition for disgorgement purposes may differ from the capital gains calculations for tax purposes. The disposition of any disgorged profits will be at the discretion of the Company, and the Employee will be responsible for any tax and related costs.
11.Prohibition of Short-Selling Securities
Employees may not Short Sell securities in their Personal Trading Accounts.
19
IV. Code Violations
Violations of any aspect of this Code require immediate reporting to Compliance. The CCO holds discretionary authority to revoke personal trading privileges for personal trading violations, including multiple violations of policy.
In the event an infraction has occurred, the CCO or member of the Compliance team will contact such employee and, in the event of a repeat violation, will contact their direct supervisor to discuss the infraction and any necessary corrective and/or disciplinary action to be taken. The severity of the disciplinary action taken will be determined by a variety of factors, including the nature of the infraction and the employee's history of compliance with the policies and procedures set forth in the Compliance Manual (including the Code of Ethics). Disciplinary action may include (but is not limited to) any combination of the following: email communication from the CCO or Compliance team member to the employee regarding the infraction; additional mandatory training sessions for such employee (which will focus on the compliance policies and procedures relevant to the infraction); temporary suspension of personal trading activities (if relevant to the infraction); profit disgorgement of personal trades (if relevant to the infraction); and written notice to members of Senior Management regarding the Supervised Person's infraction and any corrective action taken.
Violations of or non-compliance with any provision of the Compliance Manual may subject the firm and its Supervised Persons to regulatory actions and other consequences and may result in disciplinary action against the Supervised Person, up to and including termination of employment.
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20
Appendix A
Proprietary Funds List
|
|
Security Identifier Type (ISIN or CUSIP |
|
|
or SEDOL) CUSIP= 9 Characters, ISIN= |
Full Legal Name of Public Fund |
Ticker Symbol |
12 Characters, SEDOL= 7 Characters |
|
|
|
Asset Management One Co. Ltd US Preferred REIT Fund (Dynamic |
|
|
Hedge) |
4731414C |
JP90C000B7H9 |
|
|
|
Asset Management One Co. Ltd US Preferred REIT Fund (Hedged) |
4731514C |
JP90C000B7J5 |
|
|
|
Asset Management One Co. Ltd US Preferred REIT Fund (Non- |
|
|
Hedged) |
4731614C |
JP90C000B7K3 |
|
|
|
Nomura Global REIT Premium Currency Select Monthly Dividend |
01312124 JP |
|
|
|
|
Nomura Global REIT Premium Currency Select Semi-Annual |
|
|
Dividend |
01314124 JP |
|
|
|
|
Nomura Global REIT Premium JPY Monthly Dividend |
01311124 JP |
|
|
|
|
Nomura Global REIT Premium JPY Semi-Annual Dividend |
01313124 JP |
|
|
|
|
AMG Managers CenterSquare Real Estate Fund Class I |
MRASX |
00170J698 |
|
|
|
AMG Managers CenterSquare Real Estate Fund Class N |
MRESX |
00170J748 |
|
|
|
AMG Managers CenterSquare Real Estate Fund Class Z |
MREZX |
00170J680 |
|
|
|
State Street Real Estate Securities V.I.S Fund (formerly GE |
|
|
Investments Real Estate Securities Fund) |
SSRSX |
361972607 |
|
|
|
OFP GE European Fund |
|
|
|
|
|
Griffin Institutional Access Real Estate Fund Class A |
GIREX |
39822J102 |
|
|
|
Griffin Institutional Access Real Estate Fund Class C |
GCREX |
39822J201 |
|
|
|
Griffin Institutional Access Real Estate Fund Class I |
GRIFX |
39822J300 |
|
|
|
Griffin Institutional Access Real Estate Fund Class L |
GLREX |
39822J409 |
|
|
|
SEI Institutional Managed Trust - Real Estate Fund Class F |
SETAX |
783925472 |
|
|
|
SEI Institutional Managed Trust - Real Estate Fund Class I |
SEIRX |
783925373 |
|
|
|
SEI Institutional Managed Trust - Real Estate Fund Class Y |
SREYX |
78413L878 |
|
|
|
BNY Mellon Global Real Estate Securities Fund Class A |
DRLAX |
05588F816 |
|
|
|
BNY Mellon Global Real Estate Securities Fund Class C |
DGBCX |
05588F824 |
|
|
|
BNY Mellon Global Real Estate Securities Fund Class I |
DRLIX |
05588F832 |
|
|
|
Version 3.0
Columbia Funds Variable Series Trust II - CTIVP - CenterSquare Real Estate Fund
CF GLOBAL REAL ESTATE SECURITIES FUND
EB GLOBAL REAL ESTATE FUND
EB U.S. REAL ESTATE SECURITIES FUND
PineBridge US REIT Mother Fund Code
VA US REIT Mother Fund 1
22
Appendix B
Approved Brokers List
1.Charles Schwab
2.E-Trade
3.Fidelity
4.Interactive Brokers
5.Merrill Lynch
6.Morgan Stanley
7.TD Ameritrade
8.UBS AG
9.Vanguard
10.Wells Fargo Advisors
11.JP Morgan*
12.Raymond James
13.Janney Montgomery Scott
*CenterSquare Compliance should be consulted prior to opening an account with JP Morgan.
Note: The Approved Broker List is subject to change as CenterSquare Compliance may determine a need to add or remove approved brokers to meet regulatory requirements.
23
Appendix C
Initial/Annual Employee Certification
ACKNOWLEDGMENT OF RECEIPT OF COMPLIANCE MANUAL, CODE OF ETHICS, INSIDER TRADING POLICIES & ANNUAL CERTIFICATION
Please specify: |
Initial Report |
or |
Annual Renewal |
1.Acknowledgement
I acknowledge that I have received a copy of the current Compliance Manual, Code of Ethics, and Securities Firewall Policies, and I represent that:
a.I have read its terms and understand that I am fully subject to its provisions.
b.I have specifically read the Code of Ethics and I understand that it applies to me and to all Reportable Securities in which I have or acquire a Direct or Indirect Ownership. I have read the definitions of "Direct Ownership" and "Indirect Ownership" contained within the Code of Ethics, and I understand that I may be deemed to have Indirect Ownership in Reportable Securities owned by members of my household and that transactions effected by members of my household may therefore be subject to this Code of Ethics.
c.I agree that in case of a violation, I may be subject to various possible sanctions (pursuant to both the Code of Ethics and the Compliance Manual) and as determined by the Chief Compliance Officer and/or Board of Directors (or its delegate). Possible sanctions include verbal and written warnings, fines, trading suspensions, reversal of trades by which I agree to disgorge and forfeit any profits or absorb any loss on prohibited transactions, termination of employment, civil referral to the Securities and Exchange Commission, and criminal referral.
d.I will comply with the Compliance Manual, Code of Ethics, and the Securities Firewall Policy in all respects.
CenterSquare personnel provide training on the Compliance Manual and Code of Ethics annually to each Covered Person. However, each person is responsible for understanding and complying with both the Compliance Manual and Code of Ethics of his/her own volition.
_________________________________________________________
Signature |
Date |
___________________________________________
Printed Name
24
Global Code of Ethics
and Standard of Conduct
Personal Investments
Outside Activities
Gifts and Business Entertainment
Political Contributions
Other Policy Highlights
Message from Our Co-CEOs
The success of Dimensional Fund Advisors can be traced directly back to our firm's first two guiding principles: Act in the best interest of clients, and act ethically and legally. These beliefs have helped us set the industry standard in exceptional service and build lasting partnerships with our clients.
These strong relationships, some spanning over 30 years, are built on trust
treating our clients as we would want to be treated and always doing what we say we are going to do. We take our fiduciary obligation seriously and continually work to act as stewards of our clients' assets, free from conflicts of interest.
Our firm's commitment to integrity makes us stand out in a financial industry where competitive pressures are intense to behave otherwise. Dimensional will never compromise its principles or its compliance with laws and regulations, and we depend on our employees, as representatives of the firm, to uphold our ideals.
Please read this guide to learn the rules that influence our decisions and enable us to maintain the highest legal and ethical standards. Your cooperation with our code of ethics and standard of conduct will guarantee our reputation well into the future. We would like to thank you for your continued dedication to Dimensional and to our clients, which in turn allows us to continue providing for your success.
Dave Butler |
Gerard O'Reilly |
Co-Chief Executive Officer |
Co-Chief Executive Officer and |
|
Chief Investment Officer |
Table of Contents
Introduction |
|
Reporting Code and Standard of Conduct Violations ................................. |
6 |
Certification Requirements .............................................................................. |
6 |
Sanctions ........................................................................................................... |
6 |
Code of Ethics |
|
Who is subject to the Code? ........................................................................... |
8 |
Covered Accounts ............................................................................................ |
8 |
New Accounts ................................................................................................... |
9 |
Authorized Brokerage Firms U.S. Employees |
|
and U.S. Persons Subject to the Code.......................................................... |
9 |
Non-Reportable Accounts ............................................................................. |
10 |
Personal Securities Transactions................................................................. |
10 |
Private Placements......................................................................................... |
11 |
Reportable Transactions (transactions which do not require |
|
pre-clearance, but must be reported) .......................................................... |
11 |
Personal Trading Restrictions and Prohibited Activities ........................... |
12 |
Reporting Requirements................................................................................ |
14 |
Summary of Reporting Obligations .............................................................. |
14 |
Communications with Disinterested Trustees and Outside Directors..... |
15 |
Japan Supplement.......................................................................................... |
15 |
DIMENSIONAL FUND ADVISORS
4
Standard of Conduct
Outside Activities ............................................................................................
16
Guidelines
17
Approval Process
17
Gifts and Business Entertainment................................................................
18
Gifts
18
Business Entertainment 19
Political Contributions.....................................................................................
20
Other Policy Highlights...................................................................................
22
Policy Against Bribery and Corruption
22
Privacy Policies 22
Glossary of Terms..................................................................................................
23
Appendix A List of Authorized Brokerage Firms ............................................
27
Introduction
All of us at Dimensional are responsible for maintaining the very highest ethical standards when conducting business. In keeping with these standards, we should adhere to the spirit as well as the letter of the law. Dimensional's Global Code of Ethics (the "Code") and Standard of Conduct (the "Standard of Conduct") are designed to help ensure that our actions are consistent with these high standards.
The Code and the Standard of Conduct have been adopted by Dimensional pursuant to SEC Rules with the objectives of promoting:
n honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
n full, fair, accurate, timely and understandable disclosure in reports and documents filed with relevant global regulatory agencies and in other public communications made by Dimensional;
n compliance with applicable governmental laws, rules, and regulations;
n the prompt internal reporting of violations of the Code and the Standard of Conduct to the Global Chief Compliance Officer ("Global CCO") and the Deputy Chief Compliance Officer ("Designated Officer"); and
n accountability for adherence to the Code and the Standard of Conduct.
Adherence to the Code and the Standard of Conduct is a basic condition of employment. Whether or not a specific situation is addressed, you must conduct yourself in accordance with the general principles of the Code and Standard of Conduct and in a manner that is designed to avoid unlawful conflicts of interest. Failure to comply could result in disciplinary action, up to and including termination.
DIMENSIONAL FUND ADVISORS
6
INTRODUCTION
Reporting Code and Standard of Conduct Violations
Dimensional is committed to fostering a culture of compliance. If you have
any questions or concerns, or become aware of a violation or potential
violation of the Code or the Standard of Conduct, you are required to
report the matter to one of the following:
n The Global CCO and/or Designated Officer
n General Counsel or
n a member of the Ethics Committee
The Global CCO will receive reports on all violations of the Code reported
to a Designated Officer and/or a member of the Ethics Committee.
You have the option of reporting compliance-related matters on a
confidential basis through the Compliance Reporting System ("CRS"),
or by email at Compliance@dimensional.com .
Retaliation against any employee for reporting compliance-related issues is
cause for appropriate corrective action up to and including termination of
the retaliating employee.
General Code or Standard of Conduct questions should be directed to your
local Compliance Team members.
Certification Requirements
You are required to complete a Code of Ethics and Standard of Conduct
Acknowledgement Form upon commencement of your employment with
Dimensional, and annually thereafter, to acknowledge and certify that you
have received, reviewed, understand and shall comply with the Code and
the Standard of Conduct. In addition, any material amendments to the
Code or the Standard of Conduct will be communicated to you and you
will be required to acknowledge your receipt and understanding of any
such amendments as a condition of your continued employment.
Sanctions
Depending on the severity of the infraction, you may be subject to
sanctions for violating the Code and related personal trading controls
(e.g., failure to pre-clear transactions, report accounts, and submit
statements and/or initial, quarterly and annual certification forms) or the
Standard of Conduct. Sanctions may include, but are not limited to:
n verbal or written warnings,
n letters of reprimand,
DIMENSIONAL FUND ADVISORS
7
INTRODUCTION
n suspension of personal trading activity,
n disgorgement and forfeiture of profits,
n suspension, and/or
n termination of employment
Immaterial violations will be communicated to your supervisor, Department
Head, and the Global CCO for corrective action. Material violations will be
escalated to the Ethics Committee and may be subsequently reported to the
Boards of Directors of the Dimensional Entities, as well as the directors/
trustees of the Dimensional Managed Funds, as required, or other persons
or entities as determined by one or more of the Dimensional Entities in their
sole discretion.
Code of Ethics
Who is subject to the Code?
The Code applies to all Dimensional employees, directors/trustees, officers and general partners, all of whom are considered Access Persons. In addition, certain provisions of the Code apply to Immediate Family Member(s) living in the same household.
Restrictions on personal investment transactions may also be applied to temporary personnel (i.e., interns, contractors or consultants) whose tenure exceeds ninety (90) days and/or who have access to nonpublic systems.
Covered Accounts
You are required to report all investment accounts (i.e., Covered Accounts) with which you, your spouse, domestic partner, child or any other Immediate Family Member have Beneficial Ownership or interests.
Covered Securities
Brokerage Accounts
Discretionary Accounts1
Employee Stock
Retirement Accounts
Compensation Plans
(IRAs or local equivalent)
Transfer Agent Accounts
Mutual Fund Accounts
(such as a Computershare account)
(i.e., collective investment schemes)
Wrap Accounts
UTMAs or UGMAs
Code of Ethics, Insider
529 Accounts, in which
Trading and Compliance
you direct investments in
Manual Acknowledegments
Dimensional Managed Funds
1. Discretionary Accounts must be disclosed and supporting documentation must be provided to Compliance.
DIMENSIONAL FUND ADVISORS
9
CODE OF ETHICS
Other Covered Securities
Contract for Difference Accounts
Self-Invested Personal Pension (SIPPs)
(CDAs) (UK-specific)
and Stock & Shares ISAs (UK-specific)
Superannuation Accounts
Nippon (Japan) Individual Savings
(managed, SMSF or Super Wrap)
Account (NISA) (Japan-specific)
(Australia-specific)
Local supplementary or mandatory provident funds or retirement schemes
(i.e., CPF accounts in Singapore; MPF accounts in Hong Kong)
New Accounts
You must promptly report any new Covered Account for yourself, your spouse, domestic partner, child or any other Immediate Family Member. Unless the Account has been reported, no personal securities transactions can occur within the Account.
The U.S. Compliance Team will send a standard letter to U.S. broker- dealer(s) or bank(s), requesting duplicate statements and confirmations. However, it is your responsibility to ensure that duplicate statements and confirmations (or the local equivalent) are provided promptly. Confirmations should be provided within ten (10) calendar days.
Authorized Brokerage Firms U.S. Employees and U.S. Persons
Subject to the Code
You are required to maintain your Covered Account(s) with an Authorized Brokerage Firm. A list of Authorized Brokerage Firms, which is subject to change from time to time, is included in Appendix A. Exceptions must be approved by the Global CCO or Designated Officer. However, if you began your employment on or before August 15, 2019, and maintained one or more Covered Accounts with a brokerage firm other than an Authorized Brokerage Firm on that date, you may continue to maintain those previously reported and approved Covered Accounts.
In addition, the following types of accounts do not need to be maintained with an Authorized Brokerage Firm: mutual fund accounts, 529 accounts, 401(k) accounts, and accounts held directly with an issuer. The Global CCO may amend the list of Authorized Brokerage Firms from time to time.
DIMENSIONAL FUND ADVISORS
10
CODE OF ETHICS Non-Reportable Accounts
You do not need to report the following accounts as Compliance has independent access to these records for monitoring and verification purposes:
n Dimensional 401(k) account (or local equivalent);
n Dimensional Health Savings Accounts (HSAs);
n Dimensional Managed Fund accounts established through Fund Operations; and
n If applicable, holdings in Dimensional's privately issued shares.
Although these accounts do not need to be reported, investment activities in these accounts must comply with the standards of conduct embodied in the Code.
Personal Securities Transactions
You must pre-clear any personal securities transactions in Covered
Securities prior to execution.2 This also applies to transactions by any
Immediate Family Member of the Access Person.
All personal securities transaction reports and requests for pre-clearance must be processed through Dimensional's compliance reporting system (CRS), a web-based compliance system. Compliance will evaluate and review each pre-clearance transaction request and notification will be provided to employees through the CRS, in a timely manner.
Pre-clearance approval is valid for T+1 (i.e., market orders), from the time of approval. In addition, you are required to provide confirmations (or the local equivalent) for each approved and executed transaction.
Covered Securities
Stocks/Shares
Fixed Income Securities (excluding
(common, preferred or restricted)
certain Sovereign Government issuances)
Exchange Traded Funds (ETFs) must
Dimensional Advised or Sub-advised
be pre cleared if the value of the
Exchange Traded Funds (ETFs) must be
transaction is >$25,000 (USD)
pre-cleared, regardless of the amount
of the transaction
Depository Receipts (ADRs or GDRs)
Closed-End Funds and REITs
2.Designated Officers (other than the Global CCO) are required to receive prior written approval of their personal securities transactions from
Dimensional's Global CCO. The Global CCO is required to receive prior approval of his personal securities transactions from one of the Dimensional Co-Chief Executive Officers.
DIMENSIONAL FUND ADVISORS
11
CODE OF ETHICS
Derivatives
Voluntary Corporate Actions
(options, futures, forwards, etc.)
Private Placements (documentation
Limited Partnerships and limited
must be provided)
liability company interests
Warrants & Rights
Convertible Securities
Exempt Securities
Shares of registered open-end
Bankers' acceptances, bank certificates
investment companies
of deposit, commercial paper, and high
(i.e., open-end mutual funds)
quality short-term debt instruments
(including repurchase agreements)
Direct obligations of the U.S. Government, or direct obligations of a "Sovereign Government" (e.g., Government of the United Kingdom, Commonwealth Government of Australia, etc.)
Shares issued by a unit investment trust that are invested exclusively in one or more registered open-end investment companies (none of which are Dimensional Managed Funds)
Shares of money market funds
Privately issued shares of the Advisor.
Private Placements
You may not purchase a private placement unless approved by the Global CCO or Designated Officer. Approval would be based upon a determination that the investment opportunity was not being offered to you due to your employment with Dimensional, along with other relevant factors. Each private placement pre-clearance is reviewed on a case-by- case basis.
Reportable Transactions (transactions which do not require pre- clearance, but must be reported)
Although the following transactions do not require pre-clearance, you must report them through the CRS on a quarterly basis:
n Dimensional Managed Funds (through a third -party service provider or financial advisor);
n Investments in any funds sub-advised by Dimensional;
n 529 Accounts that hold or are exclusively made up of Dimensional Funds;
n Automatic Investment Plans (including dividend reinvestment plans) in which regular periodic purchases (or withdrawals) are made automatically
DIMENSIONAL FUND ADVISORS
12
CODE OF ETHICS
in (or from) investment accounts in accordance with a predetermined
schedule and allocation; and
n Exchange Traded Funds (ETFs), other than Dimensional-advised or
sub-advised ETFs, where the principal value of the transaction is less than
or equal to USD $25,000.
Please note: Although transactions in ETFs in amounts less than or equal
to USD $25,000 do not require pre-clearance, post-trade review will be
performed and all other Code provisions will still apply, such as the sixty
(60) day profit restriction.
Personal Trading Restrictions and Prohibited Activities
The following transactions are prohibited:
n Initial public offering (IPO) investments;
n Short selling of securities;
n Transactions in securities that are subject to firmwide restriction; and
n Transactions in a security while in possession of insider information. Such
transactions are unethical and illegal and will be dealt with decisively
(reference the Global Insider Trading Policy, the EU Market Abuse Policy ,
the Singapore Supplemental Insider Trading Policy, and the Japan Insider
Trading Management Policies ).
You are prohibited from executing personal investment transactions with
individuals with whom business is being conducted on behalf of certain
institutional clients. Therefore, Compliance may request the name of the
account contact (or agent) before processing the pre-clearance request.
B L A C KO U T P E R I O D R E S T R I C T I O N
n A pre-clearance request involving a covered security will be denied if
Dimensional has traded in the same or equivalent security within the past
seven (7) calendar days, and the pre-clearance request is in an amount
over USD $10,000. Any transaction in a covered security in an amount less
than or equal to USD $10,000 still must be pre-cleared and reported, with
the exception that transactions in ETFs not managed by Dimensional only
require pre-clearance if the transactions are in an amount greater than
USD $25,000.
n Compliance will monitor trading activity for seven (7) calendar days
following the pre-clearance approval date for conflicts of interest on
non-Discretionary Accounts.
DIMENSIONAL FUND ADVISORS
13
CODE OF ETHICS
S H O R T - T E R M T R A D I N G R E S T R I C T I O N S
n Access Persons cannot profit from the purchase and sale (or sale
and purchase) of the same or equivalent security within sixty (60) calendar
days.
n Gains are calculated based on a last-in, first-out (LIFO) method.
E X C E S S I V E T R A D I N G I N C O V E R E D S E C U R I T I E S
Dimensional discourages employees from engaging in excessive trading
activity. Compliance has the discretion to notify you and/or an appropriate
supervisor of excessive trading patterns if circumstances warrant.
E X C E S S I V E T R A D I N G O F D I M E N S I O N A L M A N A G E D F U N D S
Employees are prohibited from engaging in excessive trading of any
Dimensional Managed Funds in order to take advantage of short-term
market movements. Excessive trading activity, such as a frequent
pattern of exchanges, could result in harm to shareholders or clients.
E T F S F O R W H I C H D I M E N S I O N A L S E R V E S A S A D V I S O R O R S U B A D V I S O R
Employees with knowledge of the composition of the underlying ETF
constituents are prohibited from using such information or from disclosing
such information to any other person, except as authorized in the course
of their employment, until such information is made public.
C R Y P T O C U R R E N C I E S
When seeking to acquire a digital currency, either directly or in the form of a
security, please be aware of the following:
n If you purchase or sell a digital currency considered to be a "security"
within the meaning of the U.S. federal securities laws (or any other
applicable laws for non-U.S. personnel), you need to pre-clear the
transaction just as you would any other Covered Security. Likewise,
if you purchase or sell a fund or other instrument that invests in a digital
currency (e.g., Bitcoin Investment Trust ("GBTC")), you need to pre-clear
the transaction just as you would any other covered security.
n As with any initial public offering (IPO), your participation in an Initial Coin
Offering or Initial Token Offering (ICO), is not permitted under the Code.
n Holding or transacting in actual cryptocurrency that has been
determined not to constitute a security within the meaning of the U.S.
federal securities laws (or any other applicable laws for non-U.S.
personnel), including holding or transacting in Bitcoin or Ethereum, does
not require pre-clearance or reporting to Compliance.
DIMENSIONAL FUND ADVISORS
14
CODE OF ETHICS
E X C E P T I O N S T O C O D E R E S T R I C T I O N S
In cases of hardship, the Global CCO or Designated Officer may grant an exception (or waiver) to the personal trading restrictions of the Code. The decision will be based on a determination that a hardship exists and the transaction for which the exception (or waiver) is requested would not result in a conflict with our clients' interests or violate any other policy embodied in the Code. Any exception (or waiver) will be evidenced in writing and will be reported to the Ethics Committee.
Reporting Requirements
All personal securities transactions and holdings reports will be reviewed by Compliance. The records and reports created or maintained pursuant to the Code are intended solely for internal use and are confidential unless required to be disclosed to a regulatory or governmental agency.
New employees who fail to submit their Compliance New Hire Questionnaire and Initial Holdings Report within ten (10) calendar days of their employment start date will be prohibited from engaging in any personal securities transaction until such report is submitted and may be subject to other sanctions.
Summary of Reporting Obligations
New Hires
All Employees
Upon joining the firm
Quarterly and Annually
(Due 30 calendar days after
(Due in 10 calendar days)
each quarter)
New Hire Questionnaire
Quarterly and Annual
(Disciplinary Action Disclosure)
Compliance Questionnaires
Initial Holdings Report
Quarterly Transaction Reports and
(include private placements)
Annual Holdings Certification
Provide Covered Account
Covered Account(s) Certification;
statement(s) (current, within
report new accounts upon opening.
45 days prior to start date)
Code of Ethics, Insider Trading
Code of Ethics, Insider Trading
and Compliance
and Compliance
Manual Acknowledegments
Manual Acknowledgements
DIMENSIONAL FUND ADVISORS
15
CODE OF ETHICS Communications with Disinterested Trustees and Outside Directors
Dimensional attempts to keep directors/trustees informed with respect to Dimensional's investment activities through reports and other information provided to them in connection with board meetings and other events.
However, it is Dimensional's policy not to communicate specific trading information and/or advice on specific issues to Disinterested Trustees and Outside Directors unless the proposed transaction presents issues on which input from the Disinterested Trustees or Outside Directors is appropriate (i.e., no information is given regarding securities for which current activity is being considered for clients). Any information requests by Disinterested Trustees or Outside Directors should be reported to the General Counsel or the Global CCO.
Disinterested Trustees are not subject to the reporting requirements except to the extent the Disinterested Trustee knew or, in the ordinary course of fulfilling his or her duties as a director, should have known that during the fifteen (15) days immediately before or after the Disinterested Trustee's transaction in a Covered Security, a U.S. Mutual Fund purchased or sold the covered security, or an Advisor considered purchasing or selling the covered security for a U.S. Mutual Fund.
Japan Supplement
Pursuant to local rules and regulations, Japanese employees have additional restrictions on personal trading (see the Japanese Code of Ethics Addendum ) .
Standard of Conduct
This Standard of Conduct is designed to foster compliance with applicable legal and regulatory requirements and to require that employees act in a manner that is consistent with the highest ethical standards. Adherence to the Standard of Conduct is a basic condition of employment. Whether or not a specific situation is addressed below, you must conduct yourself in accordance with the general principles of the Standard of Conduct and in a manner that is designed to avoid unlawful conflicts of interest. Failure to comply could result in disciplinary action, up to and including termination.
Outside Activities
Certain types of outside business activities may cause a conflict of interest or an appearance of a conflict of interest. There is no absolute prohibition on a Dimensional employee participating in certain outside activities, such as charitable foundations and endowments, provided your participation does not present a conflict of interest and you comply with the Standard of Conduct. However, as a practical matter there may be circumstances in which it would not be in Dimensional's best interest to allow an employee to participate in activities with an outside organization, even if the employee's participation did not violate Dimensional's policies and procedures (such as whether the activity would absorb a good part of the employee's time, potentially affecting their performance at Dimensional).
It is impossible to anticipate every conflict of interest that may arise, but activities with outside organizations should be limited to those that either do not present or have the least potential of presenting conflicts of interest. As a result, Dimensional requires that outside business and charitable activities must be approved by your supervisor and Compliance prior to the acceptance of such a position (or if you are new, upon joining the firm).
DIMENSIONAL FUND ADVISORS
17
STANDARD OF CONDUCT Guidelines
S E R V I N G O N T H E B O A R D S O F P U B L I C C O M PA N I E S
n As a general matter, directorship or (an equivalent position) in an unaffiliated public company (or companies reasonable expected to become public companies) will not be authorized because of the potential conflicts.
n If you wish to accept a directorship or (an equivalent position), you must obtain prior approval from the Boards of Directors of the Dimensional Entities in which you are an employee and/or an officer.
A C T I V I T I E S W I T H A P R I V A T E O R G A N I Z A T I O N
n If you wish to be involved with a private organization (non-Dimensional) in an official capacity (officer, directorship or an equivalent position), you must obtain approval from the Co-CEOs and the Global CCO.
A C T I V I T I E S W I T H A N O N - P R O F I T O R G A N I Z A T I O N
n If you wish to be involved with a non-profit organization in an official capacity (directorship or an equivalent position), you must notify Compliance in writing as further approval may be required.
C O M P E N S A T I O N
n If you receive compensation from an outside organization, you must obtain prior written approval from your supervisor and Compliance.
Approval Process
Outside activity requests will be evaluated on a case-by-case basis and approval will be granted only if it is determined that the activity does not present a significant conflict of interest. Obtain written approval from your supervisor with the activity details and copy your local Compliance Team designee(s). If any additional information is required, Compliance will reach out to you.
In instances where you receive authorization to serve as a director on an outside organization, you are expected to refrain from any direct (or indirect) involvement in the consideration by a Dimensional client of any purchase or sale for securities of that outside organization (or any affiliates of the outside organization) for which you serve as a director.
DIMENSIONAL FUND ADVISORS
18
STANDARD OF CONDUCT
Gifts And Business Entertainment
If you accept or provide gifts or entertainment (including business entertainment) relating to Dimensional business, you must comply with regulatory requirements, Dimensional's business practices, and the Standard of Conduct. The giving (or accepting) of gifts and entertainment may create (or appear to create) a conflict of interest and place Dimensional or a client in a difficult or embarrassing position. Therefore, embarrassing gifts should never be given (or accepted), and you always should use your best judgment when giving (or accepting) any gift or entertainment to determine whether it is appropriate.
Under certain circumstances, Section 17(e)(1) of the 1940 Act may prohibit Dimensional's Fund Advisory Personnel from accepting gifts and entertainment from Broker Donors. Accordingly, Dimensional has adopted additional restrictions that apply when Broker Donors offer gifts and entertainment to Authorized Traders. If you are a member of Fund Advisory Personnel, you must comply with these additional restrictions.
Gifts
In general, you may give (or accept) gifts that do not exceed the annual aggregate amount of USD $100 (or the local currency equivalent). However, you must be mindful that some clients (or prospective clients) may be subject to additional regulatory restrictions or prohibitions on the acceptance of gifts or entertainment and may have to comply with related disclosure requirements. Therefore, you should inquire about any restrictions or disclosure requirements, prior to giving any gifts (or providing business entertainment). The giving (or accepting) of all Gifts and Business Entertainment must be reported and logged promptly. Please contact a member of your local Compliance Team for reporting details. ( U.S. employees refer to the designee(s) list on Be.Dimensional.)
Gifts include logo items (e.g., pens, hats, etc.), tickets for events, gift baskets, meals and transportation.
This policy does not apply to gifts or charitable donations made by you outside the scope of your responsibilities with Dimensional.
G I F T R E S T R I C T I O N S
n
n
You may not give (or accept) gifts in excess of USD $100 (or the local currency equivalent).
You may not give (or accept) gifts in the form of cash or cash equivalents.
DIMENSIONAL FUND ADVISORS
19
STANDARD OF CONDUCT n Gifts valued in excess of USD $100 must be reported to Compliance and returned unless an exception is granted by the Global CCO or Compliance Designee.
n No exceptions will be granted for gifts subject to FINRA's USD $100 gift limit.
If you are a member of Fund Advisory Personnel, you must also comply with the following restrictions:
n You may not accept any gifts from Broker Donors except gifts of de minimis value, such as non-lavish, logoed items or gifts of less than USD $25 in reasonably estimated value. If you have a long-standing personal relationship with a Broker Donor, you may attend a non- business, social event hosted by the Broker Donor, or accept a non-de minimis gift or entertainment greater in value than USD $25 from the Broker Donor if the event, gift, or entertainment is pre-approved first by your supervisor and then Compliance. You must report all gifts from Broker Donors regardless of value.
Business Entertainment
Business entertainment includes any event, meal or activity whose primary purpose is business and is offered by and attended by a person who
has (either directly or through their employer or affiliate) a current or prospective business relationship with Dimensional. This also includes instances where a Dimensional employee is offering the event, meal or activity on behalf of a current or prospective Dimensional client or vendor. If the person (or entity) paying for the entertainment does not have a representative in attendance, the event constitutes as a gift and is subject to the gift restrictions above.
P R O V I D I N G B U S I N E S S E N T E R TA I N M E N T
You may provide business entertainment as long as it is appropriate and reported in writing to your supervisor. Business entertainment provided to a current or a prospective client or vendor will be overseen by your supervisor through the Dimensional expense reporting and approval process. If the business entertainment exceeds USD $100 per person, you will need to provide to your supervisor a written explanation along with the name of the client, business vendor or organization.
R E C E I V I N G B U S I N E S S E N T E R TA I N M E N T
You may receive business entertainment as long as it is appropriate and reported in writing to your supervisor. If the estimated value of the business entertainment you receive is expected to exceed USD $100 per person,
DIMENSIONAL FUND ADVISORS
20
STANDARD OF CONDUCT you will need to report the event in writing to the head of your department. The following types of business entertainment require pre-approval by your department head:
n Attending business-related events with an expected value in excess of USD $100 per person (or the local equivalent);
n Meals or events in which family members or friends are present; and
n Attending meals or events in which five (5) or more Dimensional employees are in attendance.
If you are a member of Fund Advisory Personnel, you must also comply with the following restrictions:
n You may not accept entertainment (such as sporting events) from Broker Donors. You may accept business meals from Broker Donors of less than USD $100 in anticipated value, and you must report those meals to your supervisor and Compliance. You may accept business meals from Broker Donors of greater than USD $100 in anticipated value provided you first pre-clear the meal with your supervisor and Compliance.
U N I O N S A N D U N I O N O F F I C I A L S
Special reporting rules apply when Dimensional employees furnish any gift or entertainment in excess of USD $250 in any calendar year to labor unions, union officials, agents or consultants of a Taft-Hartley plan. Please report all gifts or entertainment involving a union or union official to either Legal or Compliance. If applicable, Legal will be responsible for filing the required LM-10 form with the Department of Labor.
S U P P L E M E N TA L P O L I C I E S
n Japan Addendum to Gift and Entertainment
Political Contributions
The U.S. Securities and Exchange Commission's political contribution regulation and FINRA's Rule 2030, also known as "pay to play" rules3, limit contributions4 by investment advisers and certain of their employees to certain Covered Government Officials. In addition, Dimensional is subject to a variety of federal, state and local restrictions regarding political contributions, as well as contractual restrictions between Dimensional and certain clients.
3.Political Contributions by Certain Investment Advisors, Rule 206(4)-5; Engaging in Distribution and Solicitation Activities with Government Entities, FINRA Rule 2030.
4.Contributions include, but are not limited to, monetary contributions, gifts and loans (including in-kind contributions, such as donation of goods or services).
DIMENSIONAL FUND ADVISORS
21
STANDARD OF CONDUCT Although Dimensional encourages civic and community involvement by its directors, officers and employees, Dimensional desires to avoid any situation that could curtail Dimensional's current business or business prospects, raise potential or actual conflicts of interest, or create an appearance
of impropriety in the context of Dimensional's business relationships. Accordingly, all contributions by a director, officer, employee or Immediate Family Member of a director, officer or employee of Dimensional (each a "Contributor"), must be made on the Contributor's behalf, entirely voluntary, and should not be in an amount (determined by Contributor taking into account the Code) that is likely to influence a candidate's judgment regarding any continued or future business with Dimensional.
Specifically, this policy prohibits a Contributor from making political contributions when the solicitation or request for such contributions implies that continued or future business with Dimensional depends on making such contributions. Similarly, no contributions should be made that create the appearance that Dimensional stands to benefit in its business relations because of the Contributor's contribution. If a Contributor is unsure if a particular political contribution would be in compliance with this policy, they should consult Dimensional's U.S. Legal and/or Compliance Department.
More specifically, the following actions are prohibited:
n Contributors are prohibited from making political or charitable contributions for the purpose of obtaining or retaining potential or existing public entity clients;
n Contributors are prohibited from making any contributions that create the appearance that Dimensional stands to benefit in its business relations because of such contribution; and
n Contributors from Dimensional's non-U.S. based advisor affiliates are prohibited from making any political contributions to political action committees (PACs) federal, state or local candidates for elective office in the United States.
In order to prevent an inadvertent violation of the "pay to play" rules, Contributors are prohibited from making political contributions without prior approval from the Global CCO or DCCO to any of the following:
n Covered Government Officials
n Political action committees (PACs)
DIMENSIONAL FUND ADVISORS
22
STANDARD OF CONDUCT Requests for approval of political contributions must be submitted through the CRS and cannot exceed Federal, state or client limitations. Dimensional's Compliance Department will be responsible for maintaining the required books and records associated with employee political contributions to ensure the reports are kept confidential. In addition, Dimensional's Global CCO or a Chief Executive Officer may grant exceptions to the contribution limitation on a case-by-case basis. Violations of this policy will not necessarily be deemed to be violations of the "pay to play" rules; all violations of this policy will be discussed by Dimensional's Global Legal and Compliance Officers in making that determination. If you have any questions about the policy, please contact the U.S. Legal and/or Compliance Department.
Other Policy Highlights
Policy Against Bribery and Corruption
Dimensional employees are prohibited from giving, offering or promising anything of value to a foreign official with the intent to improperly obtain or retain any business or any other advantage.
For a full explanation of the policy, please refer to the Bribery and
Corruption Policy and the supplemental policies for the following:
n Anti-Corruption Policy (U.K.)
Privacy Policies
You should be aware of your local privacy policies, Dimensional Privacy Policy and Procedures , Dimensional Fund Advisors Ltd. , Australian Privacy Policy Statement, relevant Irish Privacy Policy and Notice , the Japan Personal Information Protection Policies and the Singapore Privacy Policy . Information concerning Dimensional's clients that you acquire in connection with your employment at Dimensional is proprietary. As an employee, contractor or consultant you have access to computers, systems and corporate information in order to do your job. This access means that you have an obligation to use these systems responsibly and follow company policies to protect information and systems.
You are prohibited from sending or forwarding sensitive or confidential data to your personal email address.
If you have any general questions about the Standard of Conduct, please contact a member of your local Compliance Team.
DIMENSIONAL FUND ADVISORS
Glossary of Terms
The following definitions apply throughout both the Code and Standard of Conduct:
1940 Act means the Investment Company Act of 1940.
529 Account(s) (or 529 Plans) means accounts established in a college savings or other plan authorized under Section 529 of the Internal Revenue Code. A list of all 529 Plans that have the ability to hold Dimensional Managed Funds appears on Be.Dimensional and is periodically updated by Compliance.
Access Person means:
n
n
n
n
n
any director/trustee, officer or general partner of the U.S. Mutual Funds or Dimensional Entities;
any officer or director of the Distributor who, in the ordinary course of business, makes, participates in or obtains information regarding the purchase or sale of covered securities for any registered investment company for which the Distributor acts as the principal underwriter;
employees of Dimensional who, in connection with their regular functions or duties, make, participate in, or obtain information regarding the purchase or sale of covered securities, or other advisory clients for which the Advisors provide investment advice, or whose functions relate to the making of any recommendations with respect to such purchases or sales;
any natural persons in a control relationship with one or more of the U.S. Mutual Funds or Advisors who obtain information concerning recommendations made to such U.S. Mutual Funds or other advisory clients with regard to the purchase or sale of covered securities, or whose functions or duties, as part of the ordinary course of their business, relate to the making of any recommendation to U.S. Mutual Funds or advisory clients regarding the purchase or sale of covered securities; and
any Supervised Person (which may include contractors or consultants) who has access to nonpublic information regarding client securities transactions, research or portfolio holdings of any Dimensional Managed Funds.
DIMENSIONAL FUND ADVISORS
24
GLOSSARY OF TERMS Advisers Act means the Investment Advisers Act of 1940.
Advisor means Dimensional Fund Advisors LP, DFA Australia Limited,
Dimensional Fund Advisors Ltd., Dimensional Fund Advisors Canada
ULC, Dimensional Fund Advisors Pte. Ltd., Dimensional Japan Ltd. and
Dimensional Ireland Limited.
Authorized Brokerage Firms for U.S. employees and other U.S. persons subject to the Code are listed on Appendix A.
Beneficial Ownership means the employee has or shares a direct or indirect pecuniary interest in the securities held in an account. Employees have pecuniary interest in securities if they have the ability to directly or indirectly profit from a securities transaction. It is presumed that you have beneficial ownership interests in any account held individually or jointly, by you or by your Immediate Family Member or domestic partner (or an unrelated adult with whom you share your home and contribute to each other's support) including but not limited to family trusts and family partnerships (Securities Exchange Act of 1934, Rule 16a-1; 17 CFR 240.16a-1).
Broker Donors means broker-dealers or similar financial intermediaries and their employees, officers, directors, and other representatives.
Covered Account includes any broker-dealer, investment adviser, bank or other financial institutions in which an Access Person maintains an account in which any securities are held or the account has the ability to hold securities for the direct or indirect benefit of such Access Person.
Covered Government Official means any person who is, at the time of the contribution, an incumbent or a candidate for state or local government office (including any candidate for a federal office currently holding a state or local office).
Designated Officer means the Global Chief Compliance Officer or any employee from the Dimensional Entities designated by the Global CCO.
Dimensional means (i) DFA Investment Dimensions Group Inc., The
DFA Investment Trust Company, Dimensional Emerging Markets Value
Fund and Dimensional Investment Group Inc. (collectively, the "U.S.
Mutual Funds"), (ii) Dimensional Fund Advisors LP, Dimensional
Investment LLC, DFA Australia Limited, Dimensional Fund Advisors Ltd.,
Dimensional Fund Advisors Canada ULC, Dimensional Retirement Plan
Services LLC, Dimensional Fund Advisors Pte. Ltd., Dimensional Japan
Ltd., and Dimensional Hong Kong Limited, and Dimensional Ireland
Limited (collectively, the "Dimensional Entities"); and (iii) DFA Securities
LLC (the "Distributor").
DIMENSIONAL FUND ADVISORS
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GLOSSARY OF TERMS Dimensional Managed Funds means any series/portfolio of the U.S. Mutual Funds or any other fund advised by or sub-advised by any of the Advisors.
Discretionary Account means a personal account in which you have completely turned over decision-making authority to a professional money manager (who is not an Immediate Family Member or not otherwise covered by the Code) and you have no direct or indirect influence or control over the account. Such accounts are often referred to as "professionally managed" or "managed accounts."
Disinterested Trustee means a director/trustee of the U.S. Mutual Funds who is not considered to be an "interested person" of the U.S. Mutual Funds within the meaning of Section 2(a)(19)(A) of the 1940 Act.
Ethics Committee means the Ethics Committee appointed by the directors/ trustees of the Dimensional Entities and consists of the certain officers of Dimensional Fund Advisors LP , including the Co-Chief Executive Officers, General Counsel, Head of Portfolio Management, Head of Global Human Resources, Global Chief Compliance Officer and subject to change from time to time.
Fund Advisory Personnel means those persons whose names appear on the effective list of Authorized Traders kept by Dimensional.
Immediate Family Member of an employee means any of the following person(s) sharing the same household with the employee:
n spouse, civil union or domestic partner, child, stepchild, grandchild, parent, stepparent, grandparent, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in- law, adoptive relationships and legal guardianships;
n someone who holds account(s) in which the employee is a joint owner, has trading authority, or Beneficial Ownership; and/or
n someone for whom the employee contributes to the maintenance of the household and the financial support of such person.
Outside Director means a director of any Advisor who is not considered to be an "interested person" of the Advisor within the meaning of Section 2(a)(19)(B) of the 1940 Act, provided that a director shall not be considered interested for purposes of the Code by virtue of being a director or knowingly having a direct or indirect beneficial interest in the securities
of the Advisor if such ownership interest does not exceed five percent (5%) of the outstanding voting securities of such Advisor.
DIMENSIONAL FUND ADVISORS
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GLOSSARY OF TERMS SEC Rules means rules of the U.S. Securities and Exchange Commission (the "SEC") including, but not limited to, Rule 206(4)-5 and Rule 204A-1 under the Advisers Act, and Rule 17j-1 under the 1940 Act.
Supervised Person means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of Dimensional, or other person who provides (i) investment advice on behalf of an Advisor and (ii) is subject to the supervision and control of the Advisor with respect to activities that are subject to the Advisers Act or the 1940 Act.
DIMENSIONAL FUND ADVISORS
Appendix A
List of Authorized Brokerage Firms
The following Authorized Brokerage Firms, which are subject to change from time to time, are approved for U.S. employees and U.S. persons subject to the Code:
n
n
n
n
n
n
n
n
n
n
n
n
n
Ameriprise
Betterment
Edward Jones
Charles Schwab
E*Trade
Fidelity
Merrill Lynch
Morgan Stanley
Raymond James
TD Ameritrade
USAA
Vanguard
Wells Fargo
Disclosure
MKT-3914 10/19
Code of Ethics for JPMAM
Last Revision Date: December 13, 2019
Last Review Date: December 13, 2019
Effective Date: 02/01/2005
TABLE OF CONTENTS
1. |
Summary ....................................................................................................................................... |
3 |
|
2. |
Amendments to Previous Version Distributed January 30, 2019.................................................. |
4 |
|
3. |
Scope ............................................................................................................................................ |
4 |
|
4. |
Reporting Requirements................................................................................................................ |
4 |
|
|
4.1. |
Holdings Reports.................................................................................................................. |
4 |
|
4.2. |
Transaction Reports............................................................................................................. |
5 |
|
4.3 |
Exceptions from Transaction Reporting Requirements ....................................................... |
5 |
5. |
Personal Trading Requirements.................................................................................................... |
6 |
|
|
5.1 |
Approved Broker Requirement ............................................................................................ |
6 |
|
5.2 |
Blackout Provisions.............................................................................................................. |
6 |
|
5.3 |
Minimum Investment Holding Period and Market Timing Prohibition .................................. |
6 |
|
5.4 |
Trade Reversals and Disciplinary Action ............................................................................. |
7 |
6. |
Books and Records to be maintained by Investment Advisers ..................................................... |
7 |
|
7. |
Privacy ........................................................................................................................................... |
7 |
|
8. |
Anti-Corruption .............................................................................................................................. |
8 |
|
9. |
Conflicts of Interest........................................................................................................................ |
8 |
|
|
9.1 |
Trading in Securities of Clients ............................................................................................ |
8 |
|
9.2 |
Trading in Securities of Suppliers ........................................................................................ |
8 |
|
9.3 |
Pre-clearance Procedures for Value-Added Investors ........................................................ |
8 |
|
9.4 |
Gifts & Entertainment ........................................................................................................... |
9 |
|
9.5 |
Political Contributions and Activities .................................................................................. |
10 |
|
9.6 |
Charitable Contributions .................................................................................................... |
11 |
|
9.7 |
Outside Business Activities................................................................................................ |
11 |
10. |
Training ....................................................................................................................................... |
11 |
|
11. |
Escalation Guidelines ................................................................................................................. |
12 |
|
|
11.1 Violation Prior to Material Violation ................................................................................... |
12 |
|
|
11.2 |
Material Violations............................................................................................................. |
12 |
12. |
Defined Terms ............................................................................................................................. |
12 |
2
1. Summary
This Code of Ethics for JPMorgan Asset Management ("JPMAM") (the "Code") has been adopted by the registered investment advisers of JPMAM in accordance with Rule 204A-1 under the Investment Advisers Act of 1940 (the "Advisers Act"). Rule 204A-1 requires an investment adviser registered under Section 203 of the Advisers Act to establish, maintain and enforce a written Code of Ethics.
This Code establishes our standards for ethical conduct which are premised on fundamental principles of openness, integrity, honesty and trust. In addition to the Code, J.P. Morgan Chase has a firmwide Code of Conduct that applies to all employees globally, including all JPMAM employees. In the event that a difference exists between any of the standards identified in the JPMC Code of Conduct and the Code, the more restrictive provision shall apply.
JPMAM hereby adopts the message from Jamie Dimon that was included in the JPMC Code of Conduct because it embodies JPMAM's ethical standards:
"JPMorgan Chase is the respected company it is today because of our commitment to being accountable, straightforward and honest in all of our business dealings. Our people, our products and services, and our enduring dedication to integrity have made us one of the largest and most respected financial institutions in the world. It is paramount for us all not only as a company, but also as culture carriers to uphold that mission each and every day.
Our Code of Conduct reflects this shared obligation. We operate with the highest level of integrity and ethical conduct, at all times. We do the right thing even when it's not the easy thing. We have zero tolerance for unethical behavior. And, we abide by the letter of the laws and regulations everywhere we do business.
It also is important for each of us to speak up when we see something that doesn't look or feel right. We all share this responsibility, which is key to preserving and building on this proud heritage. If you know of a possible violation of the Code or other improper behavior, report it.
The Code of Conduct is a valuable resource as we continue to meet our obligations to all of our constituents customers, the Board, shareholders, regulators and ourselves.
As a company, we're only as good as our people, and our people are the best. Remember, our integrity begins with you."
Additionally, it is the duty of all Supervised Persons to act in the best interests of their clients, place the interests of JPMAM Clients before their own personal interests at all times and to avoid any actual or potential conflicts of interest. Supervised Persons are the officers, directors (or other persons occupying a similar status or performing similar functions or employees of JPMAM) or any other person who provides investment advice on JPMAM's behalf and is subject to JPMAM's supervision or control.
Supervised Persons must comply with applicable Federal Securities Laws and promptly report any known or suspected violations of the Code promptly to the Compliance Department or Code of Conduct Reporting Hotline, which shall report any such violation promptly to the Chief Compliance Officer ("CCO") of the applicable legal entity, or through the various reporting channels as provided in the How To Report A Violation page of the Code of Conduct intranet site. Your reporting obligations do not prevent you from reporting to the government or regulators conduct that you believe to be in violation of law and it does not require you to notify JPMAM prior to reporting to the government or regulators. JPMAM
3
strictly prohibits intimidation or retaliation against anyone who makes a good faith report about a known or suspected violation of the Code or any law or regulation.
Compliance with the Code, and other applicable policies and procedures, is a condition of employment. The rules, procedures, reporting and recordkeeping requirements set forth in the Code are hereby adopted and certified as reasonably necessary to prevent Supervised Persons from violating the provisions of the Code and applicable Federal Securities Rules.
The Compliance Department provides a link to this Code and any amendments to all Supervised Persons in their Access Persons Report and requires their attestation of compliance with this Code at least annually. These records are maintained by the Compliance Department as part of its Books and Records as required by the Advisers Act.
Annually, the CCO of each registered investment adviser must review that the Code adequately reflects the adviser's fiduciary obligations and those of its Supervised Persons.
2.Amendments to Previous Version Distributed January 30, 2019
∙Updated Summary to include Jamie Dimon's 2019 message;
∙Updated Section 9.4 on gifts and entertainment to more closely align with the Gifts and Entertainment Policy AM Global; and
∙Updated Section 12 to include name change of JF Asset Management Limited to JPMorgan (Asia Pacific) Ltd.
3.Scope
This Code applies to all Supervised Persons of JPMAM.
4.Reporting Requirements
4.1.Holdings Reports
Access Persons must submit holdings reports to the Compliance Department documenting current securities holdings:
a)Content of Holdings Reports
Each holdings report must contain, at a minimum:
1)Account Details
The name of any broker, dealer or bank with which the Access Person maintains a Covered Account in which any Reportable Securities are held for the Access Person's direct or indirect benefit as well as all pertinent Covered Account details (e.g., account title, account number.).
2)Account Statements
The title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each Reportable Security in which the Access Person has any direct or indirect beneficial ownership.
3)Submission Date
4
The date the Access Person submits the report to the Compliance
Department.
b)Submission of Holdings Reports
Access Persons must submit both an Initial and Annual holdings report:
1)Initial Report
Must be submitted no later than 10 days after the person becomes an Access Person and the information must be current as of a date no more than 45 days prior to the date the person becomes an Access Person.
2)Annual Report
Must be submitted at least once each 12-month period thereafter on or before January 30, and the information must be current as of a date no more than 45 days prior to the date the report was submitted, unless notified by Compliance that this is no longer required due to electronic position reporting received from Approved Brokers.
4.2.Transaction Reports
Access Persons must submit to the Compliance Department securities transactions reports on a quarterly basis, in the form designated by the Compliance Department. Securities transaction reports must meet the following requirements:
a)Content of Transaction Reports
Each transaction report must contain, at a minimum, the following information about each transaction involving a Reportable Security in which the Access Person had, or as a result of the transaction acquired, any direct or indirect beneficial ownership:
1)The date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each Reportable Security involved;
2)The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);
3)The price of the security at which the transaction was effected;
4)The name of the broker, dealer or bank with or through which the transaction was effected; and
5)The date the Access Person submits the report to the Compliance Department.
b)Timing of Transaction Reports
Each Access Person must submit a transaction report no later than 30 days after the end of each calendar quarter, which report must cover, at a minimum, all transactions during the quarter.
4.3Exceptions from Transaction Reporting Requirements An Access Person need not submit:
5
a)Any report with respect to securities held in accounts over which the Access Person had no direct or indirect influence or control;
b)A transaction report with respect to transactions effected pursuant to an Automatic Investment Plan;
c)Transaction Reports are not required for accounts maintained at Approved or Preferred Brokers or for accounts which are approved for statement tracking
d)Any report with respect to transactions in Reportable Funds.
5. Personal Trading Requirements
Supervised Persons must obtain approval from the Compliance Department before directly or indirectly acquiring Beneficial Ownership in any Reportable Security, including initial public offerings and limited offerings. Given the potential access to Proprietary and Client information that Supervised Persons may have, JPMAM and its Supervised Persons must avoid even the appearance of impropriety with respect to personal trading, which must be oriented toward investment rather than short-term or speculative trading. JPMAM's policies are designed to help prevent and detect violations of securities laws and industry conduct standards and to minimize actual or perceived conflicts of interest that could arise due to personal investing activities.
5.1Approved Broker Requirement
All self-directed Associated Accounts must be maintained with a JPMC Approved Broker. (Click on the attached link above for list of approved brokers)
5.2Blackout Provisions
The personal trading and investment activities of Supervised Persons are subject to particular scrutiny due to the fiduciary nature of the business. Specifically, JPMAM must avoid even the appearance that its Supervised Persons conduct personal transactions in a manner that conflicts with the firm's investment activities on behalf of Clients. Accordingly, certain Supervised Persons are restricted from conducting personal investment transactions during certain periods (called "Blackout Periods"), and may be instructed to reverse previously completed personal investment transactions. Additionally, the Compliance Department may restrict the personal trading activity of any Supervised Person if it is determined that such activity has the appearance of a conflict of interest.
These Blackout Periods apply varying levels of restrictions appropriate for different categories of Supervised Persons based upon their level of access to non-public Client or Proprietary information.
5.3Minimum Investment Holding Period and Market Timing Prohibition
Supervised Persons are subject to a minimum holding period, generally 60 days, for all transactions in Reportable Securities. For Reportable Funds, only named Portfolio Managers of such funds are subject to a minimum holding period.
Supervised Persons are not permitted to conduct transactions for the purpose of market timing in any Reportable Security or Reportable Fund. Market timing is defined as an investment strategy using frequent purchases, redemptions, and/or exchanges in an attempt to profit from short-term market movements.
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5.4Trade Reversals and Disciplinary Action
Transactions by Supervised Persons are subject to reversal due to a conflict (or appearance of a conflict) with the firm's fiduciary responsibility or a violation of the firm policy. Such a reversal may be required even for a pre-cleared transaction that results in an inadvertent conflict or a breach of blackout period requirements.
Disciplinary actions resulting from a violation of the Code will be administered in accordance with related JPMAM guidelines governing disciplinary action and escalation. All violations and disciplinary actions will be reported promptly by the Compliance Department to the employee's group head and senior management. Violations will be reported quarterly to the affected Fund's Board of Directors.
Violations by Supervised Persons of the Code, the JPMC Code of Conduct or any laws or regulations that relate to JPMAM's operation of its business or any failure to cooperate with an internal investigation may result in disciplinary action, up to and including immediate dismissal, including termination of regulatory registration where applicable.
6. Books and Records to be maintained by Investment Advisers
The Compliance Department is responsible for maintaining books and records, including:
a)A copy of this Code and any other code of ethics adopted by JPMAM pursuant to Rule 204A-1 that is in effect or has been in effect at any time within the past five years;
b)A record of any violation of the Code, and any Compliance action taken as a result of that violation;
c)A record of all written acknowledgments of the violation for each person who is currently, or within the past five years was a Supervised Person of JPMAM;
d)A record of each report made by Access Persons required under the Reporting Requirements;
e)A record of the names of persons who are currently, or within the past five years were Access Persons;
f)A record of any decision, and the reasons supporting the decision, to approve the acquisition or sale of securities by Supervised Persons under section 6. Pre- approval records of certain investments will be maintained for at least five years after the end of the fiscal year in which the approval is granted; and
g)Any other such record as may be required under the Code.
7.Privacy
Supervised Persons have a responsibility to protect the confidentiality of information related to Clients. This responsibility may be imposed by law, may arise out of agreements with Clients, or may be based on policies or practices adopted by the firm. Certain jurisdictions have regulations relating specifically to the privacy of individuals and/or business and institutional customers. Various business units and geographic areas within JPMC have internal policies regarding customer privacy.
The restriction on disclosing confidential information is not intended to prevent Supervised Persons from reporting to the government or a regulator any conduct Supervised Persons believe to be in violation of the law, or from responding truthfully to questions or requests from the government, a regulator or in a court of law.
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8.Anti-Corruption
It is the policy of JPMC to comply with the anti-corruption laws that apply to the firm's Operations (and investments where the firm is deemed to have control), which laws include the United States Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act of 2010 (UKBA), as well as anti-corruption laws and regulations of other countries in which the firm conducts business. We must never compromise our reputation by engaging in, or appearing to engage in, bribery or any form of corruption. Bribery and corruption are crimes with potentially severe penalties to JPMC and its employees and directors. The firm has zero tolerance for such activity.
9. Conflicts of Interest
The following is a summary of commonly identified employee conflicts of interest:
9.1Trading in Securities of Clients
Supervised Persons shall not transact in any securities of a Client with which the Supervised Person has or recently had significant dealings or responsibility on behalf of JPMAM if such investment could be perceived as effected based on confidential information, including material non-public information.
9.2Trading in Securities of Suppliers
Supervised Persons in possession of information regarding, or directly involved in negotiating, a contract material to a supplier of JPMAM may not invest in the securities of such supplier. If you own the securities of a company with which we are dealing and you are asked to represent JPMorgan Chase in such dealings you must:
a)Disclose this fact to your department head and the Compliance Department; and
b)Obtain prior approval from the Compliance Department before selling such securities.
9.3Pre-clearance Procedures for Value-Added Investors
Prior to any telephone calls, video, and in-person meetings between a Portfolio Manager, or employee arranging the meeting, and a Value-Added Investor who is meeting to discuss his/her personal investment (or prospective investment) in the JPMAM Private Investment Fund managed by the Portfolio Manager, the Portfolio Manager must obtain pre-clearance from Compliance. In order to obtain pre-clearance approval, the following information must be provided to Compliance prior to the meeting:
a)Date and place of meeting;
b)Name of Value-Added Investor, their employer, and job title;
c)Name of private fund the Value-Added Investor is invested in (or may invest in);
d)Names of all J.P. Morgan employees in attendance at the meeting and job titles;
e)Purpose of the meeting.
Compliance will review the pre-clearance request and respond via email and will ensure that appropriate controls are instituted.
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9.4Gifts & Entertainment
Supervised Persons must avoid circumstances that may cause, or create the appearance of, a conflict of interest between JPMAM and its clients or other business/commercial contacts. Supervised Persons may not give or receive anything of value, directly or indirectly, to influence improper action or obtain an improper advantage. Furthermore, the giving and receiving of gifts, including entertainment and hospitality, to or from persons who do or seek to do business with JPMAM have the potential to create actual conflicts or the appearance of conflicts, and may negatively impact JPMAM.
Gifts and entertainment can take many forms, including but not limited to: goods or services for which employees are not required to pay the retail or usual and customary cost; meals or refreshments; tickets to entertainment or sporting events; the use of a residence, vacation home or other accommodation; travel expenses; or charitable contributions or organization sponsorships. In addition to gifts and entertainment, JPMAM Supervised Persons may not make, direct or solicit any other person to make, any political contribution or provide anything else of value to anyone for the purpose of influencing or inducing the awarding or retention of investment advisory services business.
Gifts
Supervised Persons are only permitted to give gifts valued up to 100 USD to a client or business counterparty on occasions when gifts are customary, such as life events and major holidays. AM employees must pre-clear giving any gifts to a client or business counterparty that exceeds 100 USD.
When giving gifts to clients or business counterparties, AM employees are strongly encouraged to give items with a JPMorgan Chase logo or books from the JPMorgan Chase Reading list whenever appropriate. Gifting books from the JPMorgan Chase Reading List are limited to one book per campaign. Repetitive gifting to a client or business counterparty of Firm logo items in a calendar year is not permitted.
Supervised Persons have a 100 USD annual maximum limit for gifts provided to clients or business counterparties.
Entertainment
Entertainment includes business-related activities at which a host and guest are both present (e.g., meals, refreshments, golf games, sporting events, or other leisure and entertainment). Entertainment is considered a prohibited gift unless both the employee and business contact are present and the employee's participation is related to his or her position and duties within JPMAM. Spouses, family members and personal acquaintances should not participate in entertainment activities unless such participation is customary under the circumstances.
Supervised Persons may act as a host for business entertainment to clients and prospects if such entertainment is: (1) business related; (2) is not prohibited by law; and (3) in an amount that is reasonable and customary. Frequent and/or lavish business entertainment is prohibited.
Supervised Persons are limited to accepting $250 in meals and entertainment from a client or counterparty per calendar year, with limited exceptions. Once the $250 limit
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is reached, employees are required to pay for their own expenses. In addition, Supervised Persons are prohibited from accepting invitations to ticketed events; limited exceptions may be granted with pre-approval from senior management and Compliance.
All gifts and entertainment provided to U.S. Government Officials must be pre-cleared by Compliance to ensure that they comply with jurisdictional restrictions.
Supervised Persons must receive written pre-clearance from Compliance before providing any other type of Entertainment to an ERISA Plan Sponsor or Union Official aside from meals that conform to the AWM Expense Procedure (e.g., golf, sporting events, cultural or social events, concerts, leisure activities, etc.)
Supervised Persons are required to log all entertainment subject to reporting into Reliance's Gift and Entertainment Module for approval. Violations are subject to Compliance Violation Framework.
Sponsorships and Events
Both the sponsorship of distributor events and JPMAM hosting educational events for financial advisors who sell our funds are subject to the criteria below and many require the review by Compliance and regional governance committees or designees to meet criteria below.
Events
∙Events are 30 people or more to build relationships, train/educate attendees on products or services, etc.
∙Requires an Event Coordinator
∙Requires 80% training content in an event
∙Requires client correspondence from distributor home office when per person benefits exceeds $1000
∙Preclearance thresholds for Compliance vs. recordkeeping
Sponsorship
∙Requires a Sponsorship Coordinator
∙Risk based approach to pre-clearing Sponsorships regionally
9.5Political Contributions and Activities
In accordance with Advisers Act Rule 206(4)-5, Supervised Persons are prohibited from making political contributions for the purpose of obtaining or retaining advisory contracts with government entities.
To ensure compliance with this federal pay-to-play rule and various state and local laws, JPMAM Supervised Persons must receive pre-clearance before they or any members of their household make or solicit political contributions or engage in political activities in connection with any election in the United States or the Republic of Colombia.
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Contributions to JPMC Political Action Committees are excluded from pre-clearance and reporting requirements. New hires must also disclose their history of making and soliciting political contributions.
An employee cannot be reimbursed or otherwise compensated by JPMC for any political contribution. JPMC policies prohibit contributions of corporate funds to candidates, political party committees and political action committees. Supervised Persons are strictly prohibited from using JPMC resources to conduct personal political activities.
Violations of these requirements are subject to the Compliance Violation Framework.
9.6Charitable Contributions
Charitable contributions made on behalf of JPMC must adhere to the requirements of the AM Expense Procedures and be precleared with Compliance.
9.7Outside Business Activities
A Supervised Person's outside activities must not reflect adversely on the firm or give rise to a real or apparent conflict of interest with the Supervised Person's duties to the firm or its Clients. Supervised Persons must be aware of potential conflicts of interest and be aware that they may be asked to discontinue any outside activity if a potential conflict arises. Supervised Persons may not, directly or indirectly:
a)Accept a business opportunity from someone doing business or seeking to do business with JPMAM that is made available to the Supervised Person because of the individual's position with the firm;
b)Take for oneself a business opportunity belonging to the firm;
c)Engage in a business opportunity that competes with any of the firm's businesses.
More specific guidelines are set forth under the JPMC Code of Conduct. Procedures for pre-clearance of Outside Activities and Second Jobs are available on the JPMC Code of Conduct intranet site. Employees are reminded of their responsibility to obtain preclearance of their Outside Business Activities periodically in their Access Persons Report. If any material change in relevant circumstances occurs, Supervised Persons must seek clearance for a previously approved activity. A material change may arise from a change in your job or association with JPMAM or in your role with respect to that activity or organization. JPMAM employees are required to be continually alert to any real or apparent conflicts of interest with respect to investment management activities and promptly disclose any such conflicts to their manager and Compliance. Employees must also notify Compliance when any approved outside activity terminates.
Regardless of whether an activity is specifically addressed under JPMAM policies or the JPMC Code of Conduct, Supervised Persons should disclose any personal interest that might present a conflict of interest or harm the reputation of the firm.
10. Training
Compliance provides in-person and/or online training to Supervised Persons on an ongoing basis. Compliance determines the training topics that will be covered during training sessions based on the work responsibilities of Supervised Persons, applicable regulatory requirements and risk assessments. Compliance may, from time to time, distribute Compliance Bulletins reinforcing or clarifying prior guidance, communicating
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new regulatory developments or the adoption or amendment of policies, procedures or controls.
11. Escalation Guidelines
JPMC's Compliance Violation Framework is an internal Compliance document and is used to notify Group Heads, Managers and/or Human Resources (HR) of employee violations of Compliance Policies along with the assigned severity of the applicable violations.
11.1Violation Prior to Material Violation
While the Group Head is notified of all violations, he/she is required to have a meeting with the employee when the Supervised Persons' next violation would be considered material, in order to stress the importance of the requirement and inform the employee about the ramifications for not following the policy. The employee is also required to acknowledge, in writing (form to be provided by Compliance) that he/she is aware of the ramifications for noncompliance and he/she will be compliant going forward. The written acknowledgement is signed by both the employee and Group Head, and returned to Compliance for record keeping.
11.2Material Violations
All material violations require the Group Head (MD level) and Compliance to have a meeting with the employee and document in writing that the employee acknowledges the material nature of the violation and that he/she will be compliant going forward. The written acknowledgement, signed by the employee and Group Head, will be stored in Compliance's Violations records. Additionally, HR is notified of all material violations and follows their established guidelines for disciplining the employee and recording that event in the employee's personnel file.
There will be a mandated suspension of personal trading privileges for six months for all material violations of the personal trading or Access Persons requirements. Compliance and the Group Head may allow transactions for hardship reasons, but require documentation for pre-clearance.
An employee's receipt of a material violation is considered when determining the employee's annual compensation and eligibility for promotion.
12.Defined Terms
Access Persons Access Persons of JPMAM include:
1)Employees of any of the Registered Investment Advisers within JPMAM.
2)Certain persons of other affiliated entities that have access to Proprietary information of AM and persons that have been identified by Compliance as having access to AM Proprietary information;
3)All persons of entities affiliated with JPMAM that have been authorized by the Office of the Corporate Secretary to act in an official capacity on behalf of the JPMAM Registered Investment Advisers, sometimes referred to as "dual-hatted" employees; or
4)Certain consultants, agents, and temporary workers who are involved in the investment management process or have access to Proprietary information
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Connected Person
Covered Account
Automatic Investment Plan
Beneficial ownership
Client
Federal Securities Laws
Fund
Initial Public
Offering
JPMAM
regarding Client recommendations or transactions on a pre-trade or same-day basis.
Individuals who, based on their relationship with a Supervised Person, are subject to provisions of this Policy including, but not limited to:
∙The Supervised Persons' spouse, domestic partner or minor children (even if financially independent)
∙Anyone to whom the Supervised Person provides significant financial support or for which the Supervised Person, or anyone listed above, has or shares the power, directly or indirectly, to make investment decisions
Is an account in the name of or for the direct or indirect benefit of a Supervised Person or a Supervised Person's spouse, domestic partner, minor children and any other person for whom the Supervised Person provides significant financial support, as well as to any other account over which the Supervised Person or any of these other persons exercise investment discretion, regardless of beneficial interest. Excluded from Associated Accounts are any 401(k) and deferred compensation plan accounts for which the Supervised Person has no investment discretion.
Is a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An automatic investment plan includes a dividend reinvestment plan.
Is interpreted to mean any interest held directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, or any pecuniary interest in equity securities held or shared directly or indirectly, subject to the terms and conditions set forth under Rule 16a-1(a)(2) of the Securities Exchange Act of 1934. A Supervised Person who has questions regarding the definition of this term should consult the Compliance Department. Please note: Any report required under section
5.Reporting Requirements may contain a statement that the report will not be construed as an admission that the person making the report has any direct or indirect beneficial ownership in the security to which the report relates.
Is any entity (e.g. person, corporation or Fund) for which JPMAM provides a service or has a fiduciary responsibility.
Are the Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes- Oxley Act of 2002, the Investment Company Act of 1940 ("1940 Act"), the Advisers Act, Title V of the Gramm-Leach-Bliley Act (1999), any rules adopted by the Securities and Exchange Commission ("SEC") under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted there under by the SEC or the Department of the Treasury.
Is an investment company registered under the Investment Company Act of 1940.
Is an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of sections 13 or 15(d) of the Securities Exchange Act of 1934.
Is the abbreviation for JPMorgan Asset Management, a marketing name for the Asset Management subsidiaries of JPMorgan Chase & Co. Within the context of this document, JPMAM refers to the following U.S. registered investment advisers of JPMorgan Asset Management:
∙J.P. Morgan Alternative Asset Management, Inc.
∙JPMorgan Asset Management (UK) Ltd.
∙J.P. Morgan Investment Management Inc.
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Limited Offering
Proprietary
Reportable Fund
Reportable Security
Supervised Persons
ValueAdded
Investor
∙Security Capital Research & Management Inc.
∙Bear Stearns Asset Management Inc.
∙JPMorgan Funds Limited
∙JPMorgan Asset Management (Asia Pacific) Ltd.
Is an offering that is exempt from registration under the Securities Act of 1933 pursuant to section 4(2) or section 4(6) or pursuant to Rules 504, 505 or 506 there under.
Within the context of this Code of Ethics is:
1)any research conducted by AM or its affiliates
2)any non-public information pertaining to AM or its affiliates
3)all JPM managed and sub-advised mutual funds
Is any JPMorgan Proprietary Fund, including sub-advised funds
Is a security as defined under section 202(a)(18) of the Advisers Act held for the direct or indirect benefit of an Access Person, including 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, guaranty of, or warrant or right to subscribe to or purchase any of the foregoing. Excluded from this definition are:
1)Direct obligations of the Government of the United States;
2)Bankers' acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements;
3)Shares issued by money market funds; and
4)Shares issued by open-end funds other than Reportable Funds
1)Any partner, officer, director or employees of JPMAM (or other person occupying a similar status or performing similar functions).
2)All employees of entities affiliated with JPMAM that have been authorized by the Office of the Corporate Secretary to act in an official capacity on behalf of a legal entity within JPMAM, sometimes referred to as "dual hatted" employees;
3)Certain consultants, as well as any other persons who provide advice on behalf of
JPMAM and are subject to JPMAM's supervision and control;
4)All Access Persons
Is an executive level officer (i.e., president, Chief Executive Officer, Chief Financial Officer, Chief Operating Officer or Partner) or director of a company, who, due to the nature of his/her position, may obtain material, non-public information.
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C o d e o f E t h i c s
R e v . J a n u a r y 7 , 2 0 2 0
Los Angeles Capital Management and Equity Research, Inc.
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Definitions
Access Persons. Any Supervised Person who has access to non-public information regarding any clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of a Reportable Fund; or who is involved in the investment decision making process for a client, or who has access to such investment decisions for a client. Each employee of the Firm is considered an Access Person unless otherwise exempted by Los Angeles Capital's Approving Officers.
Approving Officers. Chief Compliance Officer in conjunction with any of the following: General Counsel, President, or CEO.
Automatic Investment Plan. A program in which regular periodic purchases or withdrawals are made automatically in to or from Investment Accounts in accordance with a pre-determined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.
Beneficial Ownership. Generally speaking, encompasses those situations where the beneficial owner has the right to enjoy some economic benefit from the ownership of the security or can obtain ownership of the securities immediately or within 60 days, or can vote or dispose of the securities. A person is normally regarded as the beneficial owner of securities held in the name of his or her spouse or minor children living in his or her household.
Closed End Fund. A fund which does not continuously offer their shares for sale, but rather, sells a fixed number of shares at one time (in an Initial Public Offering), after which the shares typically trade on a secondary market. The price is determined by the market and may be greater or less than the shares' net asset value.
Compliance System. Third-party compliance software used by Los Angeles Capital to record certifications and monitor activities including, but not limited, to Access Persons' personal trading, conflicts of interest, outside business interests, gifts and entertainment, etc.
Foreign Official. Includes governmental officials, political party leaders, candidates for office, employees of state owned enterprises (such as state owned banks or pension plans), and relatives or agents of such persons if a payment is made to such relative or agent of a Foreign Official with the knowledge or intent that it ultimately would benefit the Foreign Official.
Initial Public Offering (IPO). An offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before registration, was not subject to the reporting requirements of sections 13 and 15 of the Securities Exchange Act of 1934.
Investment Account. An Investment Account is considered any personal brokerage account or retirement account capable of holding a security and where the Access Person has Beneficial Ownership or direct or indirect influence or control.
Limited Offering. An offering made to a few, select individuals that is exempt from registration under the Securities Act of 1933 (e.g., hedge funds, private placements, etc.).
Non-Discretionary Account. An account over which the Access Person has no direct or indirect influence or control.
Outside Business Interest. Any significant business interest in, or an outside position with, an entity not owned by the Firm.
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Outside Entity. Any entity (including non-profits) unaffiliated with the Firm, whether publicly or privately held. This may also include unincorporated businesses or self-employment, including family or private businesses. An Outside Entity does NOT include local community organizations such as local churches, homeowners associations, clubs, or local charities.
Reportable Fund. Any fund for which Los Angeles Capital serves as an investment adviser or sub-adviser.
Reportable Security. Any security as defined in Section 202(a)(18) of the Act, except that it does NOT include: (i) direct obligations of the Government of the United States; (ii) Bankers' acceptances, back certificates of deposit, commercial paper and high quality short term debt instruments, including repurchase agreements, (iii) shares issued by money market funds; (iv) Shares issued by open-end funds other than Reportable Funds; and (v) Shares issued by unit investment trusts that are invested exclusively in one or more open-end funds, none of which are Reportable Funds.
Supervised Person. Director, officer, partner, or other person occupying similar status or performing similar functions, an employee of the Firm, and any other person who provides advice on behalf of the adviser and is subject to the adviser's supervision and control.
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I.Introduction
This Code of Ethics ("the Code") establishes the rules of conduct for Los Angeles Capital Management and Equity Research, Inc. ("Los Angeles Capital") and LACM Global, Ltd. (together, with Los Angeles Capital "the Firm") under Section 204 and Rule 204A-1 of the Investment Advisers Act of 1940, Rule 17j-1 of the Investment Company Act of 1940, and the Financial Conduct Authority Principles for Business and Conduct of Business.
II.General Principles
The Firm acts as a fiduciary to its clients and investors ("clients") and therefore has an affirmative duty of care, loyalty, honesty, and good faith to act in clients' best interests. The Firm's personnel have an obligation to uphold these duties. At a minimum, the Firm and its employees must conduct themselves in accordance with the following principles at all times:
1.You must place the interests of clients before yourself and the Firm;
2.You must conduct business with integrity;
3.You must act in a professional and ethical manner;
4.You have a duty to act with skill, competence, and diligence;
5.You have a duty to communicate with clients in a timely and accurate manner;
6.You must conduct all personal securities transactions in such a manner as to be consistent with the Code and to avoid any actual or potential conflict of interest or any abuse of an employee's position of trust and responsibility;
7.You must adequately protect client assets;
8.You must take reasonable care to organize and control the Firm's affairs responsibly and effectively, with adequate risk management;
9.You must adhere to the fundamental standard that investment advisory personnel not take inappropriate advantage of their positions;
10.You must adhere to the principle that information concerning the identity of security holdings and financial circumstance of clients is confidential;
11.Decisions affecting clients are to be made with the goal of providing suitable advice and equitable and fair treatment among clients;
12.Communications with clients or prospective clients should be candid and fulsome. They should be true and complete and not mislead or misrepresent. This applies to all marketing and promotional materials;
13.You must adhere to the principle that independence and objectivity in the investment decision making process is paramount; and
14.You must report any violations of the code to Los Angeles Capital's Chief Compliance Officer ("CCO"). If it would not be appropriate to report to the CCO, then violations should be brought to the attention of
Los Angeles Capital's General Counsel.
All employees must comply with applicable federal securities laws and Firm policies issued from time to time, and, as an adviser the Firm and its employees are prohibited from the following:
1.Employing a device, scheme, or artifice that would defraud an investment advisory client;
2.Making to a client or potential client any untrue statement of a material fact or omitting a material fact necessary in order to make the statements made not misleading;
3.Engaging in any act, practice, or course of business which operates or would operate as a fraud or deceit upon a client;
4.Engaging in a manipulative practice with respect to a client;
5.Engaging in any manipulative practice with respect to securities, including price manipulation, acting on or spreading false market rumors; or
6.Making use of any information that an employee may have become aware of by virtue of his/her relationship with a client organization. Access Persons may not conduct a transaction while aware of such
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"inside information" if the information is indeed non-public in nature and comes about through dialogue and/or interaction with an official at a publicly-traded organization.1
III.Scope of the Code
A. Persons Covered by the Code
Every employee of the Firm is considered an Access Person, unless otherwise exempted by Los Angeles Capital's Approving Officers. Consultants, interns, or other temporary employees may be considered an Access Person depending on certain factors such as length of service, nature of duties, and access to the Firm's information. Such persons will be notified if they are considered to be an Access Person.
Family Members of Access Persons
Certain family members of Access Persons are subject to the specific reporting requirements detailed in the Personal Trading Procedures section of the Code.
IV. Standards of Business Conduct
A. Conflicts of Interest
The Firm recognises that, from time to time, a conflict of interest may arise between its own interests and those of a client. The Firm requires that its clients' interests take precedence and that its Access Persons disregard any other relationship, arrangement, material interest, or conflict of interest which may serve to influence, or appear to influence, its discretionary management.
From time to time the Firm may have an interest or relationship to a transaction that either gives, or may give, rise to a conflict of interest. As a fiduciary, the Firm must not knowingly advise or deal in the exercise of discretion in relation to that transaction unless reasonable steps are taken to manage the conflict of interest to avoid impairment of that transaction. Where the Firm faces a material conflict that it is unable to manage, this fact must be disclosed to the client(s) concerned.
All conflicts and potential conflicts of interest, including interest in a transaction, should be reported to Los Angeles Capital's Compliance department via the Compliance System upon hire or upon entering into any such relationship, whichever may come first. Each reported conflict will be examined by Compliance or General Counsel to determine whether the conflict would be inconsistent with the interests of the Firm and subject to the implementation of appropriate information barriers or other procedures to isolate the involved investment personnel from investment-making decisions regarding the securities of or transactions with the company.
In determining whether a conflict of interest exists, the Firm must specifically take into account where it: (i) is likely to make a financial gain or avoid a financial loss at the expense of the client; (ii) has an interest in the outcome of the service provided to the client, or the transaction carried out on behalf of its client, which is distinct from the client's interest in that outcome; (iii) carries on the same business as the client; or (iv) receives, or will receive, from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods, or services, other than the standard commission or fee for that service. The following list includes, but is not limited to, possible conflicts:
∙Immediate family member is employed by a: o broker-dealer
o publicly traded company
1Refer to Los Angeles Capital's Insider Trading Policy for further information.
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ocritical service provider (see Compliance for a full list of Critical Service Providers) o client
o regulatory agency o investment adviser
∙Employee or family member serves on the board of directors or committee of any of the above.
∙Any material, Beneficial Ownership or interest in any of the above.
∙Executorship, trusteeship, or power of attorney privileges other than with respect to a family member.
Record of Conflicts
As its principal mechanism for identifying, managing, monitoring, and mitigating conflicts of interest, the Firm maintains a record of reported conflicts of interests, which itemizes conflicts, mitigating controls, and responsibilities.
Identified material conflicts are disclosed to clients in Form ADV Part 2A.
B. Outside Business Interest
The Firm permits employees to maintain Outside Business Interests as long as the Outside Business Interest does not: (i) create an actual or potential conflict of interest for the Firm; (ii) interfere with the employee's duties to the Firm and its clients; or (iii) jeopardize the business or reputation of the Firm. Outside Business Interests include a wide range of endeavors, including but not limited to: employment with an unaffiliated company, acting as an independent contractor or consultant, owner of an unrelated business, or serving as a director or officer of any Outside Entity.
Employees should not hold any part-time or secondary position with any Outside Entity that may create an actual or potential conflict of interest with the duties the employee performs for the Firm, regardless of whether the employee is compensated or not. A position with an Outside Entity is considered an Outside Business Interest.
Employees may not engage in Outside Business Interests without approval from their supervisor, the CCO, General Counsel, and the CEO. A request to engage in or undertake an Outside Business Interest must be submitted via the Compliance System. See Compliance for more information.
No Firm employee may accept an appointment as an executor, trustee, guardian, conservator, general partner, or other fiduciary, or any appointment as a consultant in connection with fiduciary or active money management matters, without obtaining approval from Los Angeles Capital's CCO. Securities trading by employees in any fiduciary capacity is subject to the Firm's Personal Trading Procedures.
Approval of an Outside Business Interest will be subject to the implementation of procedures to safeguard against potential conflicts of interest, such as establishing information barriers, placing securities of the company on the Firm's restricted list, or recusing yourself if the entity ever considers doing business with the Firm. Approval may be withdrawn at any time if the Firm's senior management concludes that withdrawal is in the Firm or its client's interest. Employees must provide Compliance with prompt notification any time a previously approved Outside Business Interest changes or the employee becomes aware of a conflict of interest relating to the activity. It is possible that the employee may be required to discontinue the previously approved activity.
See Compliance if you are unsure of your reporting obligations.
C. Transactions with Affiliates
Los Angeles Capital has one affiliate, LACM Global, Ltd., that provides advisory and marketing services to professional investors in Europe, the U.K., and the Middle East. Any new arrangements between the entities must
P a g e | 7
be reviewed by Compliance, Legal, and Los Angeles Capital's Board of Directors to account for any potential conflicts of interest.
D. Disciplinary Events
All employees are to promptly notify Los Angeles Capital's CCO of any disciplinary history upon hire and in the event of notice of or commencement of any regulatory, legal, or disciplinary action even if such action relates to your prior employment. The CCO is responsible for determining whether the information is material and must be reported to regulators and/or clients.
E. Prohibited Activities
Employees are prohibited from all of the following activities:
∙Using or sharing knowledge about pending, currently considered, or recent securities transactions of clients to profit personally, directly or indirectly, as a result of such transaction, including purchasing or selling such securities.
∙Disclosing to other persons any information about a client and/or former clients, including financial circumstances, security holdings, identity (unless the client has previously consented to the circumstances of the disclosure), and any advice furnished by the Firm.
∙Borrowing from clients or providers of goods or services with whom the Firm deals, except those who engage in lending in the usual course of business and then only on terms offered to others in similar circumstances, without special treatment. This prohibition does not preclude borrowing from individuals related to you by blood or marriage.
∙Giving advice to clients that may be interpreted as giving legal advice. All questions in this area should be referred to Los Angeles Capital's General Counsel.
∙Giving clients advice on tax matters, the preparation of tax returns, or investment decisions, with the exception of situations that may be appropriate in the performance of an official fiduciary or advisory responsibility, or as otherwise required in the ordinary course of your duties.
V.Gifts and Entertainment
A conflict of interest may occur when an employee's personal interests interfere or potentially interfere with responsibilities to the Firm or its clients. The overriding principle is to eliminate any conflict of interest. Accordingly, employees should not solicit, give, or accept inappropriate gifts, favors, entertainment, special accommodations, or other things of material value that could be viewed as overly generous, aimed at influencing decision-making, or making either party feel beholden to a person or a company or that in any manner would conflict with the best interests of the Firm or its clients.
A.Limits to Gifts and Entertainment Received by Employees
∙No employee may receive any gift, service, or other thing valued greater than $100 in aggregate (a
"Prohibited Gift") from any person or entity that does or hopes to do business with the Firm within a calendar year. The receipt of cash gifts is prohibited. Los Angeles Capital's CCO is authorized to make a final determination as to whether the thing of value should be considered a Prohibited Gift within the context of the Code's principles and may approve or deny requests to be able to accept any gift. An example of something that would not be considered a Prohibited Gift would be receipt of free admission to a conference hosted by one of the Firm's current vendors or service providers which is also provided to other clients at no charge.
P a g e | 8
∙No employee may accept extravagant or excessive entertainment from a client, prospective client, or any other person or entity that does or hopes to do business with the Firm.2 Employees may accept a business entertainment event, such as dinner or a sporting event, of reasonable value, if the person or entity providing the entertainment (i) is present; (ii) the entertainment is not provided as part of a quid pro quo arrangement; and (iii) the entertainment does not create a conflict of interest in relation to any client account.
B.Limits to Gifts and Entertainment Given by Employees
∙No employee may give or offer to give any gift, service, or other thing valued greater than $100 in aggregate within a calendar year to existing clients, prospective clients, or any other person or entity that does or hopes to do business with the Firm, including brokers and service providers, without the prior consent of Los Angeles Capital's Compliance department. Cash gifts are prohibited.
oThere are more restrictive rules and limitations for gifts and entertainment provided to certain state or local government plans, ERISA plans, unions and union officials, and Foreign Officials. Please see Compliance or Legal regarding specific gift giving limitations. Please note that for some clients or prospects entertainment and gifts may be required to be reported to a third party and could reflect unfavorably on the Firm or disqualify the Firm from being able to provide management services.
oState and local governments increasingly limit or prohibit gifts and entertainment to the employees, officers, board members, and consultants of their pension and other investing funds. Some prohibit providing anything of value, including any food, whether provided at a Firm facility or event or elsewhere, or transportation to and from airports by cab or private car. Failure to comply with these requirements by the Firm or its employees can lead to disqualification of the Firm from managing assets for the client, loss of management fees, or other penalties.
oGifts and contributions to elected political officials and candidates for political office are covered by special rules. See the Pay to Play Policy.
∙No employee may provide extravagant or excessive entertainment to a client, prospective client, or any other person or entity that does or hopes to do business with the Firm. Employees may provide a business entertainment event, such as dinner or a sporting event, of reasonable value, if the person or entity providing the entertainment is present and it is both necessary and incidental to the performance of the
Firm's business.
C.Broker/Dealer Entertainment
All employees are required to obtain pre-clearance from Compliance prior to accepting any entertainment from a broker/dealer by submitting a Broker Entertainment Request via the Compliance System. EACH Firm attendee/representative must submit a separate request to cover his or her participation only. Pre-clearance approval cannot be granted by the same individual seeking pre-clearance. All Broker Entertainment Requests must be submitted to the Compliance department in advance of the event.
D. Pre-Clearing and Reporting Gifts and Entertainment
Regardless of value or giver, all gifts and entertainment received are required to be logged in the Compliance System. You are advised to seek pre-approval if you are not certain whether the entertainment would be considered excessive, if you are providing a gift or entertainment to a government fund/pension plan, Union or Union Official, or ERISA fiduciary, or if you cannot judge whether a gift has a value over $100. If any unapproved
2Entertainment provided by a broker/dealer is subject to stricter requirements. Please refer to the section on Broker/Dealer Entertainment for more information.
P a g e | 9
gift is received, the recipient should either reject the gift, give the gift to Compliance who will return the gift to the giver, or if returning the gift would harm relations with the giver, Compliance will donate the gift to charity.
VI. Personal Trading Procedures
The Firm has adopted the following Personal Trading Procedures that must be followed by all Access Persons and their Related Parties where applicable. In certain circumstances, and in its discretion, Compliance may prohibit an Access Person from engaging in any personal trading activity and will communicate such prohibition or other limitations to the Access Person at hire or at the time of effect. Restrictions on personal trading do not relieve an Access Person of any reporting requirements set forth by the Code.3
A. Disclosure of Personal Accounts and Security Holdings
Each Access Person must disclose via the Compliance System all Investment Accounts and directly held Reportable Securities where he/she or a Related Party has direct or indirect Beneficial Ownership:
∙Within 10 days of being hired;
∙At account opening;
∙At the time such ownership is obtained; and
∙On a quarterly basis thereafter.
Appendix A offers guidance on account disclosure requirements specific to various account types.
Each Access Person & Related Party, where relevant, must consent to Compliance's receipt of data feeds directly via the Compliance System for all Investment Accounts.
Under the SEC Rules, a person is regarded as having Beneficial Ownership when they can either directly or indirectly benefit economically from the account OR if the securities are held in the name of a Related Party, defined as:
∙A husband, wife, or domestic partner
∙A minor child
∙A relative or significant other sharing the same house, and
∙Anyone else if the Access Person:
oObtains benefits substantially equivalent to ownership of the securities o Can obtain ownership of the securities immediately or within 60 days, or o Can vote the securities
Another example of an Access Person having Beneficial Ownership includes trades in any relative's brokerage account (not just those living in the same household) if the Access Person is authorized to make or direct trades AND can benefit economically from the account, regardless of whether the Access Person actually makes or directs the trades.
Whether you have Beneficial Ownership in the securities of a spouse, domestic partner, minor child, or relative or significant other sharing the same house can be rebutted only under very limited facts and circumstances. If you believe your situation is unique and therefore rebuts the presumption of Beneficial Ownership, you must contact the CCO for written approval.
3Certain Access Persons, such as consultants, interns, or other temporary employees, may be required to meet the Code's reporting obligations in alternative ways to the Compliance System. Where applicable, the Compliance department will work with each Access Person to determine satisfactory requirements and will be communicated at time of hire or occurrence.
P a g e | 10
If you act as a fiduciary with respect to funds and accounts managed outside of the Firm (e.g. if you act as the executor of an estate for which you make investment decisions) and have received approval to engage in such Outside Business Interest, you are deemed to have Beneficial Ownership in the assets of that fund or account. Accordingly, any securities transactions you make on behalf of that fund or account will be subject to the general trading restrictions and reporting applicable to you under the Code.
B. Permitted Investment Accounts
Access Persons and their Related Parties are only permitted to maintain Investment Accounts with the brokerages identified on LACM's Designated Brokerage List for Access Persons and Related Parties.4 Employer-sponsored retirement accounts (e.g., 401(k) and 403(b)), 529 Plans, and Compliance-approved Non-Discretionary Accounts are exempt from this requirement.
Unless written permission is granted by Compliance, Access Persons and their Related Parties are required to transition any applicable accounts within 90 calendar days from the time of disclosure to a broker on LACM's Designated Brokerage List. The transition process must begin within 30 calendar days from the date of account disclosure. Evidence that the transition has commenced may be requested by Compliance at any time on or after the 31st calendar day.
C. Pre-Clearance Procedures
Transacting in various security types, including limited offerings, must be pre-cleared via the Compliance System. Please see Appendix B for examples of the types of securities transactions that require pre-clearance, or consult Compliance if you are unsure of any pre-clearance obligations. All personal trading pre-clearance request must be approved in the Compliance System prior to execution.
Personal Trade Pre-Clearance Requests are made via the Compliance System and require the approval of a member of the Trading department AND a member of the Compliance department. Compliance retains the discretion to evaluate the circumstances of each transaction in conjunction with its corresponding trade request. Certain circumstances may require an estimated value of the transaction subject to a reasonable variance.
Pre-clearance approval cannot be granted by the same individual seeking pre-clearance. A standard approval is valid only until the end of the trading day on which approval was granted, or such shorter time as may be specified. If the trade is not executed by the end of the current trading day a new pre-clearance request needs to be submitted for approval prior to trading on any subsequent day.
Private Investments
Initial purchases by Access Persons or their Related Parties in securities of privately owned companies are required to receive pre-clearance approval from a member of the Compliance department via the Compliance System. A standard approval is valid only within thirty calendar days from the day in which approval was granted. If the company notifies you of their intent to go public, you must immediately notify Compliance. All such positions in privately owned companies and subsequent transactions need to be confirmed quarterly via the Compliance System as part of the Quarterly Reporting process.
LACM Identified Securities List
Transactions directed by Access Persons or Related Parties in securities and Reportable Funds identified on this list require pre-clearance approval prior to execution. This includes transactions directed by Access Persons or Related Parties in employer sponsored retirement accounts, as well as applicable transactions occurring in the Los Angeles Capital 401(k) Profit Sharing Plan.
4The LACM Designated Brokerage List for Access Persons and Related Parties is available via the Compliance System. Consultants, interns, or other temporary employees deemed an Access Person by Compliance may be exempt from the
Firm's Designated Brokerage requirement in certain circumstances.
P a g e | 11
Exemptions from Pre-Clearance
∙Transactions pursuant to an Automatic Investment Plan (plan contributions, dividend reinvestment plans, etc.). Note that a voluntary, initial automatic investment transaction in an account other than an employer sponsored retirement account must be pre-cleared in accordance with its security and transaction type, but all subsequent automatic investments are exempt from pre-clearance provided the schedule and security remain the same.
∙Purchases effected upon the exercise of rights issued pro rata to all holders of a class of its securities, to the extent such rights were acquired from such issuers, and sales of such rights so acquired.
∙Non-directed acquisition or sales of securities due to involuntary corporate actions, including stock dividends, splits, mergers, spin-offs, etc.
∙Receipt of gifts of securities.
∙Purchases or sales held in Compliance-approved Non-Discretionary Accounts where the employee has no direct or indirect influence or control. This includes accounts where the employee has signed over-all investment discretion to an adviser, broker, or other trustee.
∙Acquisition of shares of Los Angeles Capital by Access Persons pursuant to periodic share offerings.
∙Subsequent transactions in a Limited Offering where the initial investment received pre-clearance approval.
∙Fractional share positions that are automatically executed subject to broker discretion or account terms.
D.Prohibited Transactions
The Firm does not allow:
∙Purchases of a publicly traded client security (stock, bond, etc.);5
∙Purchase of shares through an Initial Public Offering (IPO);
∙Engaging in frequent trading of a Reportable Fund;6
∙Engaging in day trading as it may be a potential distraction from servicing clients; and
∙Undertaking personal investment transactions with the same individual employee at a broker-dealer firm on the Firm's approved brokerage roster.7
In the event that a restricted security was held prior to your employment with the Firm or prior to the addition to the Firm's restricted list, the Firm will not require you to liquidate your position but instead require pre- clearance on future transactions.
E. Quarterly Personal Brokerage Statements
Access Persons will provide the Compliance department via the Compliance System all Investment Account statements where the Access Peron has either direct or indirect Beneficial Ownership AND direct/indirect influence or control, including the investment accounts of all Related Parties. This may include such accounts as traditional brokerage accounts, IRAs, former employer sponsored retirement plans (e.g., 401(k)s or 403(b)s), etc. and must reflect all activity within the account during the quarterly period under review.
Where possible, data feeds for these accounts and their respective activity will be provided on a daily basis to the Compliance department via the Compliance System. If feeds are not possible, each Access Person will be required to submit, on a quarterly basis via the Compliance System, duplicate copies of all Investment Account
5Refer to the Firm's Restricted Securities List.
6Frequent trading of a Reportable Fund is defined as selling or repurchasing a position that was taken or sold, respectively, less than thirty days prior to the transaction. Certain funds may have more restrictive frequent trading policies. A list of the Reportable Funds is available via the Compliance System.
7Non-Discretionary Accounts and Related Parties are not subject to this prohibition. A list of prohibited individuals is available via the Compliance System.
P a g e | 12
statements where the Access Person has either direct or indirect Beneficial Ownership AND direct/indirect influence or control, including the Investment Accounts of all Related Parties.
F. Exempt Reporting Requirements
Access Persons do not need to provide statements or pre-clear transactions in Compliance-approved Non- Discretionary Accounts where the Access Person has no direct or indirect influence or control, including securities held in accounts where the Access Person may have signed over ALL investment discretion to an adviser, broker, or other trustee. However, Access Persons are required to report the existence of these accounts in the Compliance System on a quarterly basis, along with acceptable proof of the account's non-discretionary status within 10 days of being hired, at the time the account is considered to be non-discretionary, and annually thereafter. If you are uncertain as to whether this exclusion applies to you, please see Compliance for further clarification.
Ownership of shares of Los Angeles Capital allocated pursuant to periodic share offerings and 529 College Savings Plans are exempt from all reporting requirements and do not need to be disclosed in any capacity in the Compliance System.
Los Angeles Capital's 401(k) Profit Sharing Plan
Most investments available through Los Angeles Capital's 401(k) Profit Sharing Plan are exempt from reporting, with the exception of the Reportable Funds listed on the LACM Identified Securities List. Transactions in Reportable Funds that are made pursuant to an automatic investment plan, such as a plan contribution, are exempt. However, transactions in Reportable Funds that are directed by the Access Person by either a direct exchange in or out of the Reportable Fund, or through a one-time reallocation of your investment mix, require pre-clearance approval.
Access Persons are not required to provide a quarterly statement for the Los Angeles Capital 401(k) Profit Sharing Plan. Transactions in Reportable Funds will be monitored directly via transaction reports provided by the plan administrator.
G. Confidentiality
All reports submitted to Los Angeles Capital's Compliance department pursuant to the Code will remain confidential, except to the extent necessary to implement and enforce the provisions of the Code or to comply with requests for information from regulatory and law enforcement agencies.
H. Certification of Compliance with Code of Ethics
Upon hire and quarterly thereafter, each employee will certify in writing that (i) he/she received, read, and understands the Code and any applicable amendments; (ii) recognizes that he/she is subject to the Code; (iii) that he/she has complied with the requirements of the Code; and (iv) that he/she has disclosed all personal securities and transactions required to be reported pursuant to the requirements of the Code.
This certification will be made quarterly via the Compliance System. The Compliance department will provide each employee with a current copy of the Code upon hire, request, material change, and a copy will be maintained on the Compliance System for easy, continuous retrieval.
VII. Quarterly Code of Ethics Certifications
Access Persons must report via the Compliance System within 30 days of each calendar quarter-end all positions in directly held Reportable Securities, confirm all Investment Accounts for the Access Person and their Related Parties, certify to all entries made in the Compliance System, including gifts and entertainment, conflicts of interest, etc., and respond to any additional requests or certifications deemed necessary by Compliance. The
P a g e | 13
Compliance department will review all submissions for accuracy and completeness, cross checking with other required documentation.
VIII. Administration and Enforcement of Code
A. Annual Review
Compliance will review the Code at least annually for its adequacy and effectiveness. Any material amendments to the Code must be approved by Los Angeles Capital's Board of Directors and the Board of Directors of any mutual fund that Los Angeles Capital currently serves as a sub-adviser. All material amendments will be promptly communicated to Firm employees.
As a mutual fund adviser or sub-adviser, Los Angeles Capital will provide a written annual report to the Board of Directors of each mutual fund that describes any issues arising under the Code since the last report, including information about material violations of the Code and sanctions imposed in response. This report will also include discussion of any waivers that might be considered important by the Fund's Board of Directors and will certify that the Firm has adopted policies and procedures reasonably designed to prevent Access Persons from violating the Code.
B. Recordkeeping
All required documentation will be retained in accordance with Rule 204-2 of the Investment Advisers Act. Please see the Firm's Books and Records policy for further information.
C. Violations of the Code
All Access Persons must report immediately to Compliance if they: (i) suspect that another employee or anyone else working on behalf of the Firm has breached any of the General Principles outlined in this Code; (ii) believe that any of the Firm's procedures are inconsistent with the Firm's fiduciary duty or regulations; or (iii) are asked, directly or indirectly, to act in any manner inconsistent with the General Principles of the Code.
Access Persons must make sure that Related Parties covered by the Code are familiar with the requirements of the Code, particularly regarding personal trading requirements. A violation due to the actions of a Related Party constitutes a violation by the Access Person.
Material violations of the Code include violations that impact a client or are egregious, malicious, or repetitive in nature. A violation may include, but is not limited to: failure to receive pre-clearance when obligated; opening a non-permitted Investment Account; trading in restricted securities; fraudulent misrepresentation of personal securities holdings or conflicts of interest; receipt of or gifting an excessive gift or entertainment event to a client, prospective client, or any individual or entity who does business or hopes to do business with the Firm; failing to receive pre-clearance for broker entertainment; repetitive non-material violations for the same offense; non- compliance with applicable laws, rules, and regulations; fraud or illegal acts involving any of the Firm's business; material misrepresentation in regulatory filings, internal books and records, client records, or reports; activity that is harmful to a client, including its shareholders; and deviations from required controls and procedures that safeguard clients and the Firm.
Sanctions
Any violations of the Code may result in disciplinary action that Los Angeles Capital's Board of Directors and the CCO deem appropriate, including, but not limited to, a warning, fines, disgorgement, suspension, demotion, loss of responsibility, or termination of employment. In addition to sanctions, violations may result in referral to civil or criminal authorities where appropriate.
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Sanctions for Personal Trading Violations
Personal trading violations, including, but not limited to, trading without the required pre-clearance or trading restricted securities, may result in the immediate unwinding of the trade or a fine. If required, the amount of the fine will be determined by members of Los Angeles Capital's Board of Directors and the CCO. It may include the disgorgement of any profits from the trade to a mutually agreed upon charity. The trade(s) may be unwound as soon as possible upon discovery and notification of the violation.
IX. Whistleblower Policy
The Firm is committed to high ethical standards and compliance with the law in all of its operations and will deal with its regulators in an open and cooperative way. The Firm must disclose to regulators anything relating to the Firm of which a regulator would reasonably expect notice. The Firm believes that its employees are in the best position to provide early identification of significant issues that may arise with compliance with these standards and the law. The Firm's policy is to create an environment in which its employees can report these issues in good faith without the fear of reprisal.
The Firm requires employees to report illegal activity or activities that are not in compliance with the Firm's formal written policies and procedures, including the Firm's Code of Ethics, to assist the Firm in detecting and putting an end to fraud or unlawful conduct. All such reports will be treated confidentially to the extent permitted by law and investigated promptly and appropriately.
The Firm expects the Whistleblower Policy to be used responsibly. If an employee believes that a policy is not being followed because it is merely being overlooked, the normal first recourse should be to bring the issue to the attention of the party charged with the operation of the policy. In most cases, an employee should be able to resolve the issue with his or her manager, or, if appropriate, another senior member of the Firm. However, instances may occur when this recourse fails or you have legitimate reason to not notify management. In such cases the Firm has established a system for employees to report illegal activities or non-compliance with the Firm's formal policies and procedures.
An employee who has good faith belief that a violation of law or failure of compliance may occur or is occurring has a right to come forward and report under this Whistleblower Policy. "Good faith" does not mean that a reported concern must be correct, but it does require that the reporting employee believe that he or she is fully disclosing information that is truthful.
Reports may be oral, by telephone or interview, or in writing by letter, memorandum, instant message, or e-mail. The employee making the report must identify himself or herself. The employee should also clearly identify that the report is being made pursuant to the Whistleblower Policy and in a context commensurate with the fact that the Policy is being invoked. The report should be made to the following parties, in the order shown:
∙The Chief Compliance Officer, unless it would not be appropriate or that officer fails to respond; or
∙The General Counsel.
The Chief Compliance Officer and/or General Counsel, as appropriate, will consult about the investigation as required. Depending on the nature of the matters covered by the report, an officer or manager may conduct the investigation or it may be conducted by the Chief Compliance Officer, the General Counsel, or by an external party.
The investigation will be conducted diligently by any appropriate action.
The Firm understands the importance of maintaining confidentiality of the reporting employee to make the Whistleblower right effective. Therefore, the identity of the employee making the report will be kept confidential, except to the extent that disclosure may be required by law, a governmental agency, by self-regulatory
P a g e | 15
organization, or as an essential part of completing the investigation determined by the Chief Compliance Officer or General Counsel. Any disclosure shall be limited to the minimum required. The employee making the report will be advised if confidentiality cannot be maintained.
The Chief Compliance Officer will follow up on the investigation to make sure that it is completed, that any non- compliance issues are addressed. The Chief Compliance Officer will ensure that no acts of retribution or retaliation occur against the person(s) reporting violations or cooperating in an investigation in good faith.
The Chief Compliance Officer or General Counsel will report to the Firm's Board of Directors concerning the findings of any investigation they determine involved a significant non-compliance issue.
If an employee elects not to report suspected unlawful activity or a suspected violation of law to the Firm, the employee may contact the appropriate governmental authority for review and possible investigation. Nothing in any Confidentiality Agreement between an employee or former employee and the Company will be considered violated in making a report of suspected unlawful activity to a governmental authority. This includes reporting waste, fraud, or abuse related to the performance of a Government contract involving the Company to a designated investigative or law enforcement representative of a Federal department or agency authorized to receive such information (e.g., agency Office of the Inspector General).
The California Attorney General's whistleblower hotline is 800-952-5225, the SEC's whistleblower hotline is 202-551-4790, and the FCA's Whistleblowing Advice Line is +44 (0)20 7066 9200 or whistle@fca.org.uk .
Note that submitting a report that is known to be false is a violation of this Policy. The Firm will not retaliate against an individual who reports a violation as required by law.
Retaliation against an individual who reports a violation is prohibited and constitutes a further violation of the Code.
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Appendix A: Account Disclosure Matrix
Account Type |
Disclosure |
Electronic Feed |
Assets at Firm- |
Other Requirements |
|
|
|
Approved Brokerage |
|
Discretionary Investment Accounts |
Required |
Required |
Required |
New Investment Accounts are disclosed at account |
(Ex. individual/joint non-retirement, |
|
|
|
inception via the Compliance System, upon obtaining |
IRAs, HSA, Trusts, etc.) |
|
|
|
Beneficial Ownership, or upon a change from Non- |
|
|
|
|
Discretionary status. |
|
|
|
|
Access Persons and Related Parties must transition |
|
|
|
|
applicable accounts within 90 days of disclosure date |
|
|
|
|
directly to an eligible brokerage. The transition process |
|
|
|
|
must commence within 30 days from the date of account |
|
|
|
|
disclosure. |
Non-Discretionary Investment |
Required |
Not Required |
Not Required |
Non-Discretionary status is subject to Compliance approval |
Account |
|
|
|
and must be evidenced: |
|
|
|
|
1) within 10 days of hire date OR account opening OR at |
|
|
|
|
time the account is considered to be non-discretionary; |
|
|
|
|
AND |
|
|
|
|
2) on an annual basis thereafter. |
|
|
|
|
An account is considered non-discretionary only AFTER |
|
|
|
|
Compliance has provided written approval. |
Employer-sponsored retirement |
Required |
Not Required |
Not Required |
Disclosure is required at the time of hire or account |
(Ex. 401(k), 403(b), etc.) |
|
|
|
inception. Quarterly statement must be uploaded via the |
|
|
|
|
Compliance System. |
Los Angeles Capital's 401(k) Profit |
Required |
Not Required |
N/A |
Transactions are monitored for investments in securities |
Sharing Plan |
|
|
|
and Reportable Funds on the LACM Identified Securities |
|
|
|
|
List. Pre-clearance requirements are included on the LACM |
|
|
|
|
Identified Securities List. |
529 Plans |
Not Required |
N/A |
N/A |
N/A |
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Appendix B: Code of Ethics Pre-Clearance Matrix
If a security type you would like to trade is not listed below, please see Compliance for additional guidance. Transactions made pursuant to an automatic investment plan require pre-clearance at the initial investment in an investment account other than an employer sponsored retirement account (subsequent investments made pursuant to the automatic investment plan do not require pre-clearance).
Security Type |
Pre-Clearance Approval |
Bankers Acceptance |
Not Required |
Certificate of Deposits (CDs) |
Not Required |
Commercial Paper |
Not Required |
Debt |
|
All debt issued by LACM Restricted Security List |
PROHIBITED |
Commercial Paper |
Not Required |
Corporate Bonds |
Not Required |
High Quality, Short-Term Debt Instruments |
Not Required |
Municipal or Government Bond (Non Federal) |
Not Required |
Promissory Notes |
Not Required |
Digital Currency |
Not Required |
Digital Coin/Token |
Not Required |
Direct Obligations of U.S. Government |
Not Required |
Funds (Open and Closed) |
|
ETF |
Not Required |
ETFs on LACM Identified Securities List |
Required |
Closed-end Funds |
Required |
Money Market Funds |
Not Required |
Mutual Funds |
Not Required |
Mutual Funds on LACM Identified Securities List |
Required8 |
Reportable Funds on LACM Identified Securities List |
Required9 |
Unit Investment Fund or Trust |
Required |
Initial Coin Offering (ICO) |
PROHIBITED |
IPO Allocation |
PROHIBITED |
Limited or Direct Offering |
Required at time of initial investment; not required for all |
|
subsequent investments provided in same limited |
|
offering |
Options/Futures Contracts |
|
ETFs or Indices |
Not Required |
ETFS on LACM Identified Securities List |
Required |
Stocks |
Required |
Stocks on LACM Restricted Security List |
PROHIBITED |
All other options/futures contracts |
Not Required |
Repurchase Agreements |
Not Required |
Shares issued by Los Angeles Capital |
Not Required |
Stock |
|
Common Stock |
Required |
Stocks on LACM Restricted Security List |
PROHIBITED |
Preferred Stocks |
Required |
8Transactions in securities or Reportable Funds on the LACM Identified Securities List that occur as a part of an automatic investment plan in an employer sponsored retirement account do not require pre-clearance. Direct exchanges in or out of these securities, or one-time reallocations involving these securities, require pre-clearance.
P a g e | 18
MFS® Code of Ethics Policy
December 16, 2019
Personal Investing
Applies to
AllMFSfull-time,part-timeand temporaryemployeesglobally
All MFS contractors, interns and co-opswhohavebeennotifiedby Compliancethattheyaresubject to thispolicy
All MFS entities
Questions?
iComply@mfs.com
Compliance Helpline, x54290
Ryan Erickson, x54430
Elysa Aswad, x54535
For more information on administration such as regulatory authority, supervision, interpretation and escalation,monitoring,relatedpolicies, amendment or recordkeeping please click this link.
TheinherentnatureofMFS'servicesinselectingandtradingsecuritieshas the potential to create a real or apparent conflict of interest with your personal investingactivities.Asaresult,everyindividualsubjecttothispolicyhasa fiduciarydutytoavoidtakingpersonaladvantageofanyknowledgeofour clients' investmentactivities.
Followingtheletterandspiritoftherulesinthispolicyiscentraltomeeting client expectations and ensuring that we remain a trusted and respected firm.
Rules That Apply toEveryone
Your fiduciaryduty
Alwaysplaceclientinterestsaheadofyourown.Youmust
never:
TakeadvantageofyourpositionatMFStomisappropriate investment opportunities from MFS clients.
SeektodefraudanMFSclientordoanythingthatcouldhavethe effect of creating fraud or manipulation.
Mislead a client.
Account reporting obligations
Make sure you understand which accounts are reportable accounts. To determine whether an account is reportable, ask the following questions:
1Istheaccountoneofthefollowing?
- A brokerageaccount.
Anyothertypeofaccount(suchasemployeestockoptionor stock purchase plans)in which you have the ability to hold or trade reportable securities (see the list of reportable securities on page7).
Anyaccount,includingMFS-sponsoredretirementorbenefit plans,thatholdsareportablefund(seedefinitionofreportable fund on page 7 and a list of these funds on iComply).
2Is any of the following true?
You beneficially own the account.
Theaccountisbeneficiallyownedbyyourspouseor domestic partner.
Theaccountisbeneficiallyownedbyanothermemberofyour
householdsuchasaparent,siblingorchildforwhomyou providefinancialsupport,suchassharingofhousehold expenses.
Theaccountisbeneficiallyownedbyanyonewhoyouclaimas a tax deduction.
Theaccountiscontrolledbyyouoranothermemberofyour household(otherthantofulfilldutiesofemployment)for whom you provide financial support, such as sharing of household expenses.
If you answered "yes" to both questions, the account is reportable.
HELPFUL TO KNOW
Beneficial ownership
The concept of beneficial ownership is broader than that of outright ownership. Anyone who is in a position to benefit from the gains or income from, or who controls, an account or investment is considered to have beneficial ownership. This means that this policy applies not only to you, but to others that share beneficial ownership in these accounts or securities. See examples on page 6. Frequently Asked Questions on the topic can be found here .
Ensure that MFS receives account statements for all your reportableaccounts.Dependingonthetypeofaccountoryour
location,youmayneedtoprovidethemtoCompliancedirectly.
Promptlyreportanynewlyopenedreportableaccountorany existing account that has become reportable (including those at an approved broker). This includes accounts that become
reportableaccountsthroughlifeevents,suchasmarriage,divorce, power of attorney or inheritance.
ADDITIONAL REQUIREMENT FOR US EMPLOYEES
Does not include interns, contractors, co-ops, or temporary employees
Maintain your reportable accounts at an approved broker.
WhenyoujoinMFS,ifyouhaveaccountsatnon-approvedbrokers you must close them or move them to an approved broker (list available on iComply).
Inrarecases,ifyoufilearequestthatincludesvalidreasonsforan exception,wemaypermityoutomaintainareportableaccountat abrokernotontheapprovedbrokerlist(forinstance,ifyouhavea fully discretionary account).
Page 2
HELPFUL TO KNOW
Discretionary accounts and automatic investment plans
Discretionaryaccounts(accountsthataremanagedforyoubyathird-party registeredinvestmentadviserorbankortrustcompany)andtransactions made under an automatic investment plan (such as an Employee Stock Ownership Plan) are reportable, but with approval from Compliance they are:
exempt from quarterly transaction and annual holdings certifications (though you must still provideaccount statements).
exempt from the Access Person and Research Analyst/Portfolio Manager tradingrules(suchastherulesconcerningpre-clearanceandthe60-day holdingperiod)(pp.45),butyoustillmustobtainpre-approvalbefore your advisor participates in an IPO or private placement.
exempt from certain "Ethical Personal Investing" trading rules such as excessive trading and trading of MFS funds (p. 3).
Request approval for these accounts using the Account Exception form found in iComply.
Securities reporting obligations
Make sure you understand which securities are reportable securities.Thisincludesmoststocks,bonds,MFSfunds,exchange-
traded funds (ETFs), futures, options, structured products, private placements and other unregistered securities even if they are not held in a reportable account. See the table on page 7.
Report all applicable accounts, transactions and holdings timely. Use the iComply system and submit all reports by these
deadlines:
InitialAccounts&Holdingsreports:Submitwithin10calendardays ofhireoruponanaccesslevelchange.Informationaboutthese holdingsmust be no morethan45 daysold when submitted.
Quarterly Personal Transaction Report: Submit within 30 days
of the end of each calendar quarter.
AnnualHoldingsReport:Submitwithin30daysoftheendof each calendaryear.
Note that you must submit each report even if no transactions or other changes occurred during the time period.
TheQuarterlyPersonalTransactionReportsdonotneedtoinclude:
Transactionsor holdings in non-reportable securities.
Transactionsorholdingsindiscretionaryaccountsforwhich there is an approval on file with Compliance.
Involuntary transactions, such as automatic investment plans, dividendreinvestments,etc.TheAnnualHoldingsReport,however, must reflect these transactions.
ADDITIONAL REQUIREMENTS FOR APPOINTED
REPRESENTATIVES IN SINGAPORE
Provide a copy of the contract note for any trade of any security,includingreportablesecuritiesandnon-reportable securities,toSingaporeCompliance,within7daysofthetrade. CheckwithSingaporeComplianceontheinformationyoumust provide.
Ethical Personal Investing
Never trade securities based on the improper use of information,andneverhelpanyoneelsetodoso.Thisincludes
any trade based on:
InformationabouttheinvestmentsofanyMFSclient,including front-runningandtailgating(tradingjustbeforeorjustaftera similar trade for a client account).
Confidential information orinside information (information about theissuerofasecurity,orthesecurityitself,thatisbothmaterial and non-public).
Donottradeexcessively.AtMFS,personaltradingisaprivilege,not a right.It shouldnever interferewithyourjob performance.
MFSmaylimitthenumberoftradesyouareallowedduringagiven period,ormaydisciplineyoufortradingexcessively.Inaddition, frequent trading in MFS funds may trigger other penalties, as described in the relevant fund prospectuses.
Do not accept investment discretion over accounts that are not yours.Inlimitedcircumstances,andwithadvanceapprovalfrom Compliance, you may be allowed to assume power of attorney relating to financial or investment matters for another person or entity.
If you become an executor or trustee of an estate and it involves controloverasecuritiesaccount,youmustnotifyComplianceupon assuming the role, and you must meet any reporting or pre-clearance obligations thatapply.
Do not participate in any investment contest or club. This applies
whether or not any compensation or prize is awarded.
Do not trade securities that MFS has restricted. Follow MFS' instructionswhenyouarenotifiedofarestrictionindesignated securities.
DonotinvestinMFS-sub-advisedETFs.Forafulllistofthese
funds, see the iComply system.
Page 3
Only make investments in MFS open-end funds directly through MFS(oranotherentityMFSmaydesignate)unlessyouhavereceived
an exception from Compliance.
Do not participate ininitialpublicofferings (IPOs)or other limitedofferingsofsecuritiesexceptwithadvanceapproval
from MFS. This rule includes initial, secondary and follow-on offerings of equity securities and closed-end funds and new issues of corporate debtsecurities.
To request approval for an IPO or secondary offering, enter an Initial Public Offering Request using the form found on iComply. Note that approval is not typically granted, and when granted often involves strictlimits.
Never use a derivative, or any other instrument or technique, to getaroundarule.Ifaninvestmenttransactionisprohibited,then
youarealsoprohibitedfromeffectivelyaccomplishingthesame
thingbyusingfutures,options,ETFsoranyothertypeoffinancial instrument.
DonotinvestinContractsforDifferenceorengageinspread betting on financial markets. This includes any wagering on market
spreads or behaviors and any off-exchange trading.
HELPFUL TO KNOW
Changes in job status and life events
When changing jobs within MFS, ensure that you understand the rules that applytoyou.ConfirmwithyournewmanagerandCompliancewhatyour accesslevel is and what restrictionsand requirementsapply to you.
Whengoingonleave,youmustcontinuetocomplywiththispolicy unlessotherwiseapprovedbyCompliance.Whenyoureturnfrom leave you must complete any outstanding obligations.
Be cognizant of reporting obligations under this policy when life events occursuchasmarriage,divorceorinheritanceofanaccount.Consult with Compliance when uncertain.
Rules that Apply Only to Access Persons
Pre-clearing personal trades
pre-clearanceonthedayyouwanttoplacethetradebyenteringyour
WHICH ACCESS LEVEL ARE YOU?
Access Persons Most MFS personnel, including all officers and directors, are designated as Access Persons. You should consider yourself an Access Person unless it has been communicated to you by Compliance that you are not.
Research Analysts and Portfolio Managers In addition to the rules for Access Persons, these individuals are subject to additional rules, as noted on the following pages.
Compliance may designate other personnel as Access Persons. This may include consultants, contractors or interns who provide services to MFS, and
employees of Sun Life Financial Inc.
Makesureyouunderstandwhichsecuritiesrequirepre- clearance. Notethatthere aresome differences between which securitiesrequirepre-clearanceandwhichmustbereported. See the table on page 7 of this policy.
Pre-clearallpersonaltradesinapplicablesecurities.Request
Page 4
requestintheiComplysystem.Rememberthatyoumustpre- clear tradesforallofyourreportableaccounts(suchasthoseofa spouseor domesticpartner)aswellasforsecuritiesnotheldinan account.
Onceyouhaverequestedpre-clearance,waitforaresponse.Do NOT placeanytradeorderuntilyouhavereceivednoticeof approvalfor thattrade.Notethatpre-clearancerequestscanbe deniedatany time and for any reason.
Pre-clearanceapprovalsexpireattheendofthetradingdayon which they areissued.
Obtain advance approval for any private investments or other unregistered securities. This includes private
placements (investments in private companies), private investment in public equity securities (PIPES), hedge funds or other private funds, "crowdfunding" or "crowdsourcing" investments, peer-to-peer lending,pooledvehicles(suchas partnerships),InitialCoinOfferings (ICO's),Security Tokens and other similar investments.
Before investing, enter a Private Placement/Unregistered Securities ApprovalRequestfoundoniComply,anddonotactuntilyouhave received approval.
Page 5
HELPFUL TO KNOW
Not recommended: Good 'til canceled orders and buying on margin
These practices can create significant risk of policy violations.
Good 'til canceled orders may execute after your pre-clearance approval has expired. Placing day orders avoids this risk. With margin, you might not be able to receive pre-clearance approval for those securities you wish to sell to meet a margincall
Limits to personal investmentpractices
Do not take an uncovered short position. This includes selling
securitiesshort,buyingputswithoutacorrespondinglongposition and writing nakedcalls.
Do not buy and then sell (or sell and then buy) at a profit the same or equivalent reportable security within 60 calendar days.MFSmayinterpretthisruleverybroadly.Forexample,itmay
lookattransactionsacrossallofyourreportableaccountsandmay matchtradesthat arenotofthesamesize,securitytypeortax lot. Anygainsrealized inconnection withthese transactionsmustbe surrendered.Notethatthisruledoesnotapplytosecuritiesthatare not subject to pre-clearance, to accounts where a registered
investment adviser has investment discretion, or to involuntary transactions. Japan-based personnel: See rule with higher standard below.
ADDITIONAL REQUIREMENTS FOR RESEARCH ANALYSTS
including Research Associates and Portfolio Managers who may write research notes
Nevertrade(ortransferownershipof)reportablesecurities personallywhileinpossessionofmaterialinformationabout an issuer you have researched or been assigned to research
unless you have already communicated the information in a research note. Japan-based personnel: See rule with higher standard below.
Understand and fulfill your duties with regard to research recommendations. You have an affirmative duty to provide
unbiased and timely research recommendations in a research note. You must:
Disclosetradingopportunitiesforclientaccountspriortotrading personally in any securities of that issuer.
Providearesearchrecommendationifasecurityissuitableforthe client accounts even if you have already traded the security
personallyorifmakingsucharecommendationwouldcreatethe appearanceofaconflictofinterest.NotifyCompliancepromptly of any apparent conflicts, but do not refrain from making a research recommendation.
ADDITIONAL REQUIREMENTS FOR PORTFOLIO MANAGERS
including Research Analysts assigned to a fund as a portfolio manager
Never personally trade (or transfer ownership of) a reportable securitywithinsevencalendardaysbeforeorafteratradein any security or derivative of the same issuer in any client account that you manage. In practice, this means:
Contacting Compliance promptly when deciding to make a portfoliotradeinanysecurityyouhavepersonallytradedwithin thepastsevencalendardays(butdonotrefrainfrommakinga tradethatissuitableforaclientaccountevenifyouhavetraded the securitypersonally).
Refraining from personally trading any reportable securities you thinkanyofyourclientaccountsmightwishtotradewithinthe next seven calendardays.
Delayingpersonaltradesinanyreportablesecuritiesyourclient accountshavetradeduntiltheeighthcalendardayafterthemost recent trade by a client account (or longer, to be certain of avoiding any appearance of conflict of interest).
Notethatthisruledoesnotapplytosecuritiesthatarenotsubjectto pre-clearance,toaccountswherearegisteredinvestmentadviser has investment discretion or to involuntary transactions.
Neverbuyand then sell(orselland then buy),within 14 calendar days, any shares of a fund you manage.
Contact Compliance before any fund you manage invests in anysecuritiesofanissuerwhoseprivatesecuritiesyouownor iftheprivateentityentersintoamaterialtransactionwitha publicissuer.Youwillneedtodiscloseyourprivateinterestand
assist Compliance in performing review.
ADDITIONAL REQUIREMENTS FOR JAPAN-BASED
PERSONNEL
Do not buy and then sell (orsell and then buy)the same or equivalent reportable security within six months.
Nevertradepersonallyinanysecurityyouhaveresearchedin the prior 30 days or are scheduled to research in the future.
Page 6
Additional Information for all Personnel Subject to this Policy
BENEFICIAL OWNERSHIP: PRACTICAL EXAMPLES
Accounts of parents or children
Youshare ahousehold withoneor bothparents,but you donot provideany financial support to the parent(s): You are not a beneficial owner of the parents' accounts andsecurities.
Youshareahouseholdwithoneormoreofyourchildren,whetherminoror adult, and you provide financial support to the child: You are a beneficial owner of the child's accounts and securities.
Youhaveachildwholiveselsewherewhomyouclaimasadependentfortax purposes: You are a beneficial owner of the child's accounts and securities.
Accounts of domestic partners or roommates
You are a joint owner or named beneficiary on an account of which a domesticpartnerisanowner:Youareabeneficialownerofthedomestic partner's accounts andsecurities.
Youprovide financialsupport toadomesticpartner,eitherdirectly or by paying any portion of household costs: You are a beneficial owner of the domestic partner's accounts and securities.
Youhavearoommate:Generally,roommatesarepresumedtobetemporary andto have nobeneficial interest in oneanother's accounts andsecurities.
UGMA/UTMA accounts
Eitheryou or your spouseisthecustodian of aUniformGift/ Trust toMinor Account (UGMA/UTMA) for a minor, and one or both of you is a parent of theminor:Youareabeneficialowneroftheaccount.(Ifsomeoneelseisthe custodian, you are not a beneficial owner.)
EitheryouoryourspouseisthebeneficiaryofanUGMA/UTMA accountand isof majority age (for instance, 18years orolder in Massachusetts): You are a beneficial owner of the account.
Transfer on death (TOD) accounts
Youautomaticallybecometheregisteredowneruponthedeathoftheprior account owner: You are a beneficial owneras of the date the account is re- registered in your name, but not before.
Trusts
You are a trustee for an account whose beneficiaries are not immediate family members: Beneficial ownership is determined on a case-by-case basis,including whetherit constitutes anoutsidebusiness activity(seethe Outside Activities & Affiliations Policy).
Youareatrusteeforanaccount andyouorafamilymemberisabeneficiary: You are a beneficial owner of the account.
Youareabeneficiaryoftheaccountandcanmakeinvestmentdecisions withoutconsultingatrustee:Youareabeneficialowneroftheaccount.
Youareabeneficiaryoftheaccountbuthavenoinvestmentcontrol:Youare a beneficial owner as of the date the trust is distributed, but not before.
Youarethesettlorofarevocabletrust:Youareabeneficialowneroftheaccount.
Yourspouseordomesticpartnerisatrusteeandabeneficiary: Beneficial ownership is determined on a case-by-case basis.
Investment powers over an account
Youhavepowerofattorneyoveranaccount:Youareabeneficialownerasof the date you assume control of the trading or investment decisions on the account, but notbefore.
Youhave investment discretion over an account that holds, or could hold, reportablesecurities:Youareabeneficialowneroftheaccount,regardless ofthelocation,accounttypeortheregisteredowner(s)(otherthantofulfill duties of employment).
Youareservinginarolethatallowsorrequiresyoutodelegateinvestment discretion to an independent third party: Beneficial ownership is determined on a case-by-case basis.
HELPFUL TO KNOW
How we enforce this policy
Compliance is responsible for interpreting and enforcing this policy. Exceptions may only be granted by Compliance. In that capacity, Compliance reviews and monitors transactions and reports and also investigates potential violations.
The Employee Conduct Oversight Committee reviews potential violations, and where it determines that a violation has occurred, it usually imposes a penalty. These may range from a violation notice toa requirement to surrender profitsto atermination of employment, among other possibilities.
Page 7
Additional Information for all Personnel Subject to this Policy
ReportPre-clear
Accesspersonsonly
Note: Securities terminology varies widely in global markets. If a security type is not listed here or you are unsure how a security is treated under this policy, please contact Compliance directly.
Funds
Moneymarketfunds(MFSorother) |
No |
No |
|
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|
|
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Open-end funds that are advised or sub-advised by MFS (and are not money market funds) |
Yes |
No |
|
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Open-end funds that are not advised or sub-advised by MFS |
No |
No |
|
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|
|
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529 Plans holding MFS advised or sub-advised funds |
Yes |
No |
|
|
|
|
|
Closed-endfunds(includingventurecapitaltrusts,investmenttrustsandMFSclosed-endfunds) |
Yes |
Yes |
|
|
|
|
|
Exchange-tradedfunds(ETFs)andexchange-tradednotes(ETNs),includingoptions,futures,structurednotesandother |
Yes |
No |
|
derivatives related to these exchange-traded securities¹ |
|||
|
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||
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|
|
|
|
Yes |
Yes |
|
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|
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Equities |
|
|
|
|
|
|
|
SunLife Financial Inc. (publicly traded shares) |
Yes |
Yes |
|
|
|
|
|
Equitysecurities,includingrealestateinvestmenttrusts(REITS),andincludingoptions,futures,structurednotesor |
Yes |
Yes |
|
other derivatives on equities |
|||
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||
Fixed income |
|
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|
|
|
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Corporateandmunicipalbondsecurities,includingoptions,futuresorotherderivatives |
Yes |
Yes |
|
|
|
|
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US Treasurysecurities and other obligations backed by the full faith and credit of the US government |
No |
No |
|
|
|
|
|
US government agency debt obligations that are not backed by the full faith and credit of the US government (such as |
Yes |
Yes |
|
Fannie Mae, Freddie Mac, Federal Home Loan Banks, Federal Farm Credit Banks and Tennessee Valley Authority) |
|||
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|
||
Non-USgovernmentsecurities,andoptions,futuresorotherderivativesonthesesecurities. |
Yes |
Yes |
|
|
|
|
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Moneymarketinstruments,suchascertificatesofdepositandcommercialpaper |
No |
No |
|
|
|
|
|
Other types of assets |
|
|
|
|
|
|
Initialandsubsequentinvestments(includingcapitalcalls)inanyprivateplacementorotherunregisteredsecurities (including real estate limited partnerships or cooperatives)
Private MFS stock and private shares of Sun Life of Canada (US) Financial Services Holdings, Inc. Limitedofferings,IPOs,secondaryofferings
Derivatives(such as options, futures or swaps) onsecurity indexes
Derivatives(suchasoptions,futuresorswaps)oncommoditiesandcurrencies,includingvirtualcurrencies
Other types of transactions
Yes |
Yes |
No |
No |
Yes |
Yes |
Yes |
No |
Only if notified by |
|
Compliance |
|
|
No |
No |
|
|
|
Giftsofsecurities,includingcharitabledonations,transfersofownership,andinheritances |
Yes |
No |
¹
Page 8
Terms with special meanings
Within this policy, the following terms carry the specific meanings indicated below.
contract for difference A contract for difference (CFD) is a contract between an investor and an investment bank or a spread-betting firm. At the end of the contract, the parties exchange the difference between the opening and closing prices of a specified financial instrument, including shares or commodities.
involuntary transaction Transactions that are not under your direct or indirect influence or control, such as inheritances, gifts received, automatic investment plans, dividends and dividend reinvestments, corporate actions (such as stock splits, reverse splits, mergers, consolidations, spin-offs and reorganizations), exercise of a conversion or redemption right or automatic expiration of an option.
reportable funds Any fund for which MFS acts as investment advisor, sub-advisor, or principal underwriter including MFS retail funds, MFS Variable Insurance Trust and MFS Meridian funds. See the iComply system Policies & Procedures page for a current list of reportable funds.
Page 8
MORGAN STANLEY INVESTMENT MANAGEMENT PUBLIC SIDE1
CODE OF ETHICS AND PERSONAL TRADING GUIDELINES
Effective Date: December 12, 2019
1Excluding Private Side Employees and AIP Private Markets Employees. These employees should consult the IM Private Side Employee Trading and Investing Policy and the IM Private Side Code of Ethics .
2Previous versions: August 16, 2002, February 24, 2004, June 15, 2004, December 31, 2004, December 15, 2006, May 12, 2008 , August 19, 2010, September 17, 2010, February 15, 2011, March 1, 2011, September 28, 2011, June 29, 2012, September 16, 2013, October 10, 2014, March 26, 2016, December 7, 2017, December 12, 2018, and December 11, 2019.
2
I.INTRODUCTION3
A. General
The Morgan Stanley Investment Management ("MSIM") Public Side Code of Ethics (the "Code") is reasonably designed to prevent legal, business and ethical conflicts, to guard against the misuse of confidential information, and to avoid even the appearance of impropriety that may arise in connection with your personal trading and outside activities as an MSIM employee. It is very important for you to read the "Definitions" section below to understand the scope of this Code, including the individuals, accounts, securities and transactions it covers. You are required to acknowledge receipt and your understanding of this Code at the start of your employment at MSIM or when you become a Covered Person, as defined below, and annually thereafter.
B. Standards of Business Conduct
MSIM seeks to comply with the Federal securities laws and regulations applicable to its business. The Code is designed to assist you in fulfilling your regulatory and fiduciary duties as an MSIM employee as they relate to your personal securities transactions.
Fiduciary Duties. As an MSIM employee, you owe a fiduciary duty to MSIM's
Clients. This means that in every decision relating to personal investments, you must recognize the needs and interests of Clients and place those ahead of any personal interest or interest of the Firm.
Personal Securities Transactions and Relationship to MSIM's Clients. MSIM generally prohibits you from engaging in personal trading in a manner that would distract you from your daily responsibilities. MSIM strongly encourages you to invest for the long term and discourages short-term, speculative trading. You are cautioned that short-term strategies may attract a higher level of regulatory and other scrutiny. Excessive or inappropriate trading that interferes with job performance or that compromises the duty that MSIM owes to its Clients will not be tolerated.
If you become aware that you or someone else may have violated any aspect of this Code, you must report the suspected violation to Compliance immediately.
C. Overview of Code Requirements
Compliance with the Code is a matter of understanding its basic requirements and making sure the steps you take regarding activities covered by the Code are in accordance with the letter and spirit of the Code. Generally, you have the following obligations:
3This Code is intended to fulfill MSIM's requirements under Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the "Advisers Act") and Rule 17j-1 under the Investment Company Act of 1940, as amended (the
"Company Act"). Note that there is a separate Code of Ethics for the Morgan Stanley mutual fund family.
3
Activity |
Code Requirements |
Employee Securities Account(s) |
Pre-clearance, Reporting |
Personal Trading Reporting |
Pre-clearance, Holding, Reporting |
Participating in an Outside Activity |
Pre-clearance, Reporting |
Making a Private Investment |
Pre-clearance, Reporting |
You must examine the specific provisions of the Code for more details on each of these activities and are strongly urged to consult with Compliance if you have any questions.
D. Definitions
These definitions are here to help you understand the application of the Code to various activities undertaken by you and other persons related to you who may be covered by the Code. The definitions are an integral part of the Code and a proper understanding of them is essential. Refer back to these definitions as you read the Code.
"Access Persons" (for purposes of transacting in Morgan Stanley securities) is defined in the Global Employee Trading, Investing and Outside Business Activities Policy and means those individuals or divisions that, as part of their job function may receive or have access to Morgan Stanley-related material non-public information that is recurring or cyclical in nature.
"Broad-Based Exchange-Traded Funds ("ETFs")" for purposes of this Code, means exchanged-traded funds with at least US $1 Billion in assets under management that the IM Compliance Department has found to be sufficiently broad-based in the scope of their investment strategy and holdings so as to not to require pre-clearance. See Appendix A for a link to the current list of Broad-Based ETFs.
"Client" means shareholders or limited partners of registered and unregistered investment companies and other investment vehicles, institutional, high net worth and retail separate account clients, employee benefit trusts and all other types of clients advised by MSIM.
"Compliance" means your local Compliance group (New York, London, Singapore, Tokyo and Mumbai).
"Consultant" means a non-employee of MSIM who falls under the definition of a Covered Person.
"Covered Persons" means:
All MSIM Employees;
All directors and officers of MSIM;
Any person (such as certain consultants, leased workers or temporary workers) who provides investment advice to clients on behalf of MSIM, is subject to the supervision and control of MSIM or who has access to nonpublic information regarding any
4
Client's purchase or sale of securities, or who is involved in making securities recommendations to Clients, or who has access to such recommendations that are nonpublic.
Any person with responsibilities related to MSIM or who supports MSIM as a business and has frequent interaction with Covered Persons or Investment Personnel, as determined by Compliance.
Any other persons falling within the definition of "Access Person" under Rule 17j-1 of the Company Act or Rule 204A-1 under the Advisers Act (such as those supervised persons who have access to nonpublic information regarding the portfolio holdings of a client fund) and such other persons that may be so deemed by Compliance from time to time.
The definition of "Covered Person" may vary by location. Contact Compliance if you have any question as to your status as a Covered Person.
"Covered Securities" includes generally:
All equity or debt securities, including derivatives of securities (such as options, warrants and American depositary receipts):
Futures;
Commodities;
Securities indices;
Exchange-traded funds (excluding Broad-Based ETFs);
Open-end mutual funds for which MSIM acts as adviser or sub-adviser (including those funds that consist of Exempt Securities as listed in Schedule A)(but excluding stable NAV Money Market Funds4);
Closed-end funds;
Corporate and municipal bonds, and similar instruments.
Covered Securities does not include "Exempt Securities," as defined below. Refer to Schedule A for application of the Code to various security types.
"Employee" means an MSIM employee as well as his/her spouse or domestic partner, dependents and other persons for whom the employee, employee's spouse or domestic partner contributes substantial financial support.
"Employee Securities Accounts" are any accounts in your own name and other accounts you could be expected to influence or control, in whole or in part, directly or indirectly, whether for securities or other financial instruments, and that are capable of holding Covered Securities, whether or not such capability is utilized. Employee Securities Accounts include:
4Stable NAV Money Market Funds is defined in the Money Market Funds Policy and Procedures (Rule 2a-7)).
5
accounts owned by you;
accounts owned by your spouse or domestic partner;
accounts owned by your children or other relatives of you or your spouse or domestic partner who reside in the same household as you or to whom you contribute substantial financial support (e.g., a child in college that is claimed as a dependent on your income tax return or who receives health benefits through you);
accounts where you obtain benefits substantially equivalent to ownership of securities;
accounts that you or the persons described above could be expected to influence or control, such as:
joint accounts;
family accounts;
retirement accounts;
corporate accounts;
trust accounts for which you act as trustee where you have the power to effect investment decisions or that you otherwise guide or influence;
arrangements similar to trust accounts that benefit you directly;
accounts for which you act as custodian; and
partnership accounts.
"Exempt Securities" are securities that are not subject to the pre-clearance or holding requirements but are subject to reporting requirements of the Code and can be reported via the Reportable Accounts Disclosure System . Examples of Exempt Securities requiring disclosure include:
Bankers' acceptances, bank certificates of deposit and commercial paper;
Investment grade, short-term debt instruments, including repurchase agreements (which for these purposes are repurchase agreements and any instrument that has a maturity at issuance of fewer than 366 days that is rated in one of the two highest categories by a nationally recognized statistical rating organization);
Direct obligations of the U.S. Government5;
Shares held in money market funds;
Variable insurance products that invest in funds for which MSIM does not act as adviser or sub-adviser;
Open-end mutual funds for which MSIM does not act as adviser or sub-adviser; and
4Includes securities that are backed by the full faith and credit of the U.S. Government for the timely payment of principal and interest, such as Ginnie Maes, U.S. savings bonds, and U.S. Treasuries, and equivalent securities issued by non-U.S. governments.
6
Broad-Based ETFs.
Refer to Schedule A for application of the Code to various security types and additional requirements for Morgan Stanley Asia Limited employees who hold a Hong Kong Type 9 license.
"Firm" means Morgan Stanley, MSIM's parent company.
"Fully Managed Account" means an account (including fully managed Individual Savings Accounts ("ISAs") and an account managed on a discretionary basis by a professional financial adviser or investment adviser (e.g., a robo adviser)) for which an MSIM employee has authorized a professional financial advisor or investment manager, in its sole discretion, to acquire and dispose of assets held in the account. The MSIM employee may not make, directly or indirectly, any investment decision, be made aware of any such decisions before transactions are executed by the advisor or manager, or otherwise direct the advisor or manager to effect any transactions in the account. A Fully Managed Account is not considered an Employee Securities Account.
"Hong Kong Type 9 License Holder" means MSIM public side Investment Personnel housed in Hong Kong entity Morgan Stanley Asia Limited who holds a Hong Kong Type 9 license.
"Investment Personnel" means (i) MSIM employees and any other Covered Persons who obtain or have access to information concerning investment recommendations made to any Client; and (ii) any persons designated as Investment Personnel by Compliance.
"IPO" means an initial public offering of equity securities registered with the U.S. Securities and Exchange Commission or a foreign financial regulatory authority.
"Morgan Stanley Broker" means a broker-dealer affiliated with Morgan Stanley.
"Morgan Stanley Investment Management" or "MSIM" means the companies and businesses comprising Morgan Stanley's Investment Management Division, but not including the Private Side. See Schedule B for a list of those legal entities that comprise MSIM for purposes of the Code.
"Morgan Stanley securities" means equity, preferred and debt securities issued by Morgan Stanley, but excludes structured products, such as equity-linked or credit- linked notes.
"Mutual Funds" means (i) all open-end mutual funds; and (ii) similar pooled investment vehicles established in non-U.S. jurisdictions, such as registered investment trusts in Japan. For purposes of the Code, Mutual Fund does not include shares of open-end money market mutual funds (unless otherwise advised by Compliance).
"Outside Activity" means any organized or business activity conducted by a MSIM employee outside of MSIM. This includes, but is not limited to, participation on a board of directors or advisory board, including that of a charitable organization, working part-
7
time outside of MSIM, establishing a holding company for investments, establishing an LLC that invests in rental properties, or forming a limited partnership.
"Portfolio Managers" means MSIM employees who are primarily responsible for the day- to-day management of a Client portfolio.
"Private Investment" means a securities offering that is exempt from registration under certain provisions of the U.S. securities laws and/or similar laws of non-U.S. jurisdictions. It includes investments in hedge funds, private equity funds, limited partnerships, real estate, peer to peer lending clubs and private businesses.
"Proprietary or Sub-advised Mutual Fund " means any open-end Mutual Fund for which MSIM acts as investment adviser or sub-adviser.
"Research Analysts" are MSIM employees who are assigned to make investment recommendations to, or for the benefit of, any Client portfolio.
E. Grounds for Disqualification from Employment
Pursuant to the terms of Section 9 of the Company Act, no director, officer or employee of MSIM may become, or continue to remain, an officer, director or employee of MSIM without an exemptive order issued by the U.S. Securities and Exchange Commission, if such director, officer or employee:
within the past ten years has been convicted of any felony or misdemeanor (i) involving the purchase or sale of any security; or (ii) arising out of his or her conduct as an underwriter, broker, dealer, investment adviser, municipal securities dealer, government securities broker, government securities dealer, transfer agent, or entity or person required to be registered under the U.S. Commodity Exchange Act, or as an affiliated person, salesman or employee of any investment company, bank, insurance company or entity or person required to be registered under the U.S. Commodity Exchange Act; or
is or becomes permanently or temporarily enjoined by any court from: (i) acting as an underwriter, broker, dealer, investment adviser, municipal securities dealer, government securities broker, government securities dealer, transfer agent, or entity or person required to be registered under the U.S. Commodity Exchange Act, or as an affiliated person, salesman or employee of any investment company, bank, insurance company or entity or person required to be registered under the U.S. Commodity Exchange Act; or (ii) engaging in or continuing any conduct or practice in connection with any such activity or in connection with the purchase or sale of any security.
You are obligated to immediately report any conviction or injunction described here to Compliance.
II.TYPES OF ACCOUNTS/ACCOUNT OPENING REQUIREMENTS A. Employee Securities Accounts
8
Generally, you must maintain all Employee Securities Accounts that may invest in Covered Securities at a Morgan Stanley Broker or a Firm-approved third party broker. Requirements may vary in non-U.S. offices. New MSIM employees or newly designated Covered Persons must disclose their account(s) within 30 calendar days of hire and transfer their Employee Securities Account(s) to a Morgan Stanley Broker/Firm-approved third party broker as applicable in non-US jurisdictions, at their own expense, as soon as practicable (generally within 60 calendar days of becoming a Covered Person). Failure to do so is considered a significant violation of this Code.
Opening a Morgan Stanley Brokerage Account. When opening an account, you must notify the Morgan Stanley Broker that you are an Employee and that your account must be coded as an employee or employee-related account.
B. Fully Managed Account*
You may open a Fully Managed Account if the account meets the standards set forth below. In certain circumstances and with approval from Compliance, you may appoint non-Morgan Stanley managers (e.g., trust companies, banks or registered investment advisers) to manage your account.
In order to establish a Fully Managed Account, you must grant the manager complete investment discretion over your account. Pre-clearance is not required for trades in this account; however, you may not participate, directly or indirectly, in individual investment decisions or be made aware of such decisions before transactions are executed. This restriction does not preclude you from establishing investment guidelines for the manager, such as indicating industries in which you desire to invest, the types of securities you want to purchase or your overall investment objectives. However, those guidelines may not be changed so frequently as to give the appearance that you are actually directing account investments. To the extent that you become aware of a proposed transaction by the manager in these types of accounts or have personally directed or asked another person to direct trades in these accounts, you are required to pre-clear the transaction prior to execution of the trade by the manager. If the account is managed by a Firm other than Morgan Stanley, you must submit a request in the Outside Business Interests System (the "OBI System") and arrange for duplicate copies of trade confirmations and statements to be sent to Compliance.
Annually, MSIM employees will be required to attest that they have not made, directly or indirectly, any individual investment decision related to such managed account(s), nor have they directed another person to make such investments without first pre-clearing those transactions in accordance with Section III.
*Pursuant to local regulation, employees of MSIM Private Limited and IM Public Side employees of the Global In-house Centers as listed in Schedule B are prohibited from opening fully managed accounts.
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C. Other Morgan Stanley Sponsored Accounts6
You do not have to pre-clear participation in Morgan Stanley Sponsored Accounts with Compliance. However, you must disclose participation in any of these plans as part of the quarterly reporting process upon initial participation, and in annual certifications.
Examples of Morgan Stanley Sponsored Accounts include, but are not limited to, the following:
Employee Stock Purchase Plan (ESPP) (no new contributions)
Employee Stock Ownership Plan (ESOP)
Employee Incentive Compensation Plan (EICP)
Morgan Stanley Compensation Incentive Program (MSCIP)
Morgan Stanley 401(k) (401(k) Plan)
D. Non-Morgan Stanley Accounts
Exceptions to the requirement to maintain Employee Securities Accounts at a Morgan Stanley Broker are rare and require Compliance approval. If your request is approved, you will be required to ensure that duplicate confirmations and statements are sent to Compliance. Requirements may vary in non-U.S. offices.
If you open an outside account without obtaining the required Compliance pre-approval, you must immediately disclose it to Compliance. You may be required to close such account.
Maintaining a non-Morgan Stanley 401(k) plan or similar account that permits you to trade covered securities must be approved by Compliance.
E.Individual Savings Accounts ("ISAs") for employees of MSIM Ltd.
Fully Managed ISAs (i.e., an independent manager makes the investment decisions) may be established and maintained without the prior approval of Compliance, provided that you exercise no influence or control on stock selection or other investment decisions. Non-discretionary ISAs (including single company ISAs), where you make investment decisions, may only be established and maintained as long as the account is pre-approved by Compliance, duplicate statements are supplied to Compliance and applicable reporting requirements are met. Once a Fully Managed ISA is established, it must be disclosed to Compliance in the OBI System.
F. Mutual Fund Accounts
You may open an account for the purpose of transacting in open-end Mutual Funds,
6The definition of Morgan Stanley Sponsored Accounts does not include Employee Securities Accounts
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including Sub-Advised and Proprietary Mutual Funds (i.e., an account directly with a fund transfer agent) without prior approval from Compliance; however, these accounts are subject to reporting requirements of the Code and should be reported via the Reportable Accounts Disclosure System .
G. Issuer Purchase Plans
You may open an account directly with an issuer to purchase its shares, such as a dividend reinvestment plan, or "DRIP," by submitting the DRIP Form to your local Compliance group and pre-clearing the initial purchase and any sales. You must also report DRIP holdings to Compliance as part of the annual certificationprocess.
H. Investment Clubs
You may not participate in or solicit transactions on behalf of investment clubs in which members pool their funds to make investments in securities or other financial products.
I. 529 Plans
You do not have to obtain approval from Compliance to participate in a 529 plan; however, these plans should be reported via the Reportable Accounts Disclosure System .
III.TRADE PRE-CLEARANCE/RESTRICTIONS A. General
You are required to pre-clear all personal securities transactions in Covered Securities, other than transactions in Proprietary or Sub-advised Mutual Funds. Transactions involving Exempt Securities, including Proprietary and Sub-Advised Mutual Funds, do not require pre-clearance. Should an employee be made aware of a proposed transaction in a Fully Managed account or have personally directed, or asked another person to direct a trade in a Fully Managed account, the employee is required to pre-clear that trade prior to execution. See the Securities Transaction Matrix attached as Schedule A for additional information about when pre-clearance is required. In keeping with the general principles and objectives of the Code, Compliance, in its sole discretion, may refuse to grant approval of a personal securities transaction, without specifying a reason for the refusal.
Personal trade requests will be denied if there is an open order for any Client in the same security or related security at the time the personal trade request is submitted. Exceptions are granted if the Covered Security is being purchased or sold for a passively-managed index fund or index portfolio.
Any transaction that is prohibited by the Code may be required to be reversed and any profits (or any differential between the sale price of the personal security transaction and the subsequent purchase or sale price by a Client during the relevant period) subject to disgorgement. See "Enforcement and Sanctions" below.
B. Initiating a Transaction
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Pre-clearance is obtained by entering your trade request into the Trade Pre-Clearance system (type "IMTPC/" into your intranet browser). Upon completion of the necessary checks and approval workflows, you will receive a system generated email notification advising whether your trade request has been approved or rejected..
C. Pre-Clearance Valid for One Day Only
If your trade request is approved, such approval is valid only for the day on which it is granted7. Any transaction not completed on that day will require a new approval. This means that open orders, such as limit orders and stop-loss orders, must be pre-cleared each day until the transaction is effected. 8
D. Restrictions and Requirements for Portfolio Managers and Investment Personnel
No purchase or sale transaction may be made in any Covered Security or a related investment (i.e., derivatives) by a Portfolio Manager for a period of seven calendar days before or seven calendar days after the Portfolio Manager purchases or sells the security on behalf of a Client. A Portfolio Manager may request an exception from the blackout period if the Covered Security was traded for an index fund or indexportfolio.
Investment Personnel who have knowledge of a Portfolio Manager's trading activity are subject to the same seven day blackout period. Investment Personnel must obtain approval from their manager or his/her designee prior to obtaining pre-clearance by Compliance.
E. Employees Designated to be "Above the Wall"
MSIM employees in the MSIM Legal and Compliance Division and the MSIM Global Risk
&Analysis are designated to be "Above the Wall" ("ATW") and their personal securities transactions are subject to additional pre-clearance checks with the Control Group. Other employees may also be subject to the ATW checks as deemed necessary by Compliance.
F. Transacting in Morgan Stanley Securities
Transacting in, including the gifting of, Morgan Stanley securities must take place during designated window periods. Consult MS Today for the window period announcement prior to trading. Except as noted below for Access Persons, if you are transacting in Morgan Stanley securities through a brokerage account, you are not required to pre-clear the transaction with Compliance. Similarly, you do not have to pre-clear transactions in Morgan Stanley securities sold out of your Morgan Stanley Sponsored Accounts. All other holding and reporting requirements for Covered Securities still apply.
7The day that you receive an email informing you that the trade request was approved.
8In the case of trades in international markets where the market has already closed, transactions must be executed by the next close of trading in that market.
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As noted above, transactions in Morgan Stanley securities effected by MSIMJ employees are subject to a six month holding period.
Additional Restrictions for Access Persons Transacting in Morgan Stanley Securities. All transactions in Morgan Stanley securities must occur during the designated 30-day open window period each quarter. Compliance communicates the open and closed window periods applicable to Access Persons each quarter. During an open window period, Access Persons are required to pre-clear transactions in Morgan Stanley securities through the trade preclearance system, IMTPC. This includes transactions made in the Morgan Stanley stock fund of the 401(k) Plan or shares held externally from previous Firm-sponsored plans (e.g., Computershare, Equiniti).
Positions in Morgan Stanley securities must be held for a minimum of 30 calendar days. A six-month holding period applies to the Firm's Management and Operating Committee members for positions in Morgan Stanley securities. Shares received as part of equity- based compensation are exempt from the holding period requirements. You are prohibited from buying or selling Morgan Stanley securities if you are in possession of material, non- public information regarding Morgan Stanley.
G. Trading Derivatives
You may not trade futures, forward contracts, including currency forwards, physical commodities and related derivatives, over-the-counter warrants or swaps. You are prohibited from selling ("writing") a put. The following is a list of permitted options trading:
Call Options
Listed Call Options. You may purchase a listed call option if the call option has a "period to expiration" of at least 30 calendar days from the date of purchase and you hold the call option for at least 30 calendar days prior to sale. If you choose to exercise the option, you must also hold the underlying security delivered pursuant to the exercise for 30 calendar days.
Covered Calls. You may also sell (or "write") a call option only if you have held the underlying security (in the corresponding amount) for at least 30 calendar days.
Put Options
Listed Put Options. You may purchase a listed put option if the put option has a "period to expiration" of at least 30 calendar days from the date of purchase and you hold the put option forat least 30 calendar days prior to sale. If you purchase a put option on a security you already own, you may exercise the put once you have held the underlying security for 30 calendar days. If you purchase a put on a security that you do not own, you may not exercise the put; and must sell the option prior to its expiration date.
You must obtain pre-clearance from Compliance to exercise an option or purchase or sell an option.
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H. Other Restrictions
Primary and Secondary Public Offerings. You and your Employee Securities Account(s) are generally prohibited from purchasing any equity security in an initial or secondary/follow on public offering. In addition, unless otherwise notified by Compliance, you may not purchase an equity security that is part of a primary or secondary public offering that the Firm is underwriting or selling until the distribution has been completed. This restriction does not apply to rights issuances to which Employee Securities Accounts would be entitled with regard to their existing holdings. Note that this restriction also applies to your immediate family, regardless of whether the securities are purchased into an Employee Securities Account.
Purchases of new issue debt are permitted, provided such purchases are pre-cleared by Compliance and meet other relevant requirements of the Code.
Short Sales. You may not engage in short selling of Covered Securities.
Restricted List. You may not transact in Covered Securities that appear on the Firmwide Restricted List. Please check the Restricted List at the time of submitting a TPC request. Cross Trades: MSIM employees are not allowed to engage in cross trades or pre-arranged trades between MSIM funds or accounts and the MSIM employee's Security Accounts.
Changes to normal settlement cycles: Hong Kong Type 9 License Holders are not permitted to make changes to normal settlement cycle or delay settlement for any trades in Employee Security Accounts.
I. Other Activities Requiring Pre-Clearance
The following activities also require pre-clearance:
Outside Activities
Transactions in Private Investments
Political Contributions
J. Additional Large Trading Clearance for Employees in Asia Pacific and Japan
Before executing a securities transaction that exceeds USD 500,000 (or its currency equivalent) or where the cumulative value of current transaction and all transactions in the same issuer within a 30 day calendar window exceeds USD 500,000 (or its currency equivalent), all MSIM employees in Asia Pacific and Japan are required obtain additional large trade pre-clearance by completing the form in the policy link provided below and email a copy to "asialargetrades":
Additional Large Trade Clearance for Employee Trades in Asia Pacific
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Additional Large Trade Clearance for Employee Trades in Japan
Please note this approval requirement is in addition to the Trade pre-clearance requirement via the TPC system referred to in Section B above.
IV. HOLDING REQUIREMENTS AND REPURCHASE LIMITATIONS
A. Proprietary and Sub-advised Mutual Funds
You may not redeem or exchange Proprietary or Sub-Advised Mutual Funds until at least 30 calendar days from the purchase trade date.
B. Covered Securities
You may not sell a Covered Security until you have held it for at least 30 calendar days. If you sell a Covered Security, you may not repurchase the same security for at least 30 calendar days.
C. Holding Requirements Specific to MSIMJ Employees
When selling equity and equity-linked notes, Covered Persons at MSIMJ must hold such instruments for at least six months; however, Compliance may grant an exception if the instruments are held for at least 30 calendar days from the date of purchase. This includes transactions in Morgan Stanley securities.
D. Holding Requirements Specific to HK Type 9License Holder Employees
All personal account investments (including Exempt Securities) made by Hong Kong Type 9 License Holders are required to be held for a minimum of 30 calendar days.
V.REPORTING REQUIREMENTS
A. Initial Reporting and Certification
When you commence employment with MSIM or otherwise become a Covered Person, you must provide an Initial Disclosure Form (the "Initial Report") to Compliance no later than 10 calendar days after you become a Covered Person. The information you provide must not be more than 45 calendar days old from the day you became a Covered Person and must include:
the title and type, and, as applicable, the exchange ticker symbol or CUSIP number, number of shares and principal amount of any Covered Security;
the name of any broker-dealer, bank or financial institution where you maintain an account in which any securities are held;
15
any Outside Activities; and
the date you submitted the Initial Report.
All new Covered Persons will receive training on the principles and procedures of the Code. As a Covered Person, you must also certify that you have read, understand and agree to abide by the terms of the Code, including but not limited to, the disclosure of Outside Accounts, Outside activities and Private Investments that are required to be logged in the Outside Business Interest system within 30 calendar and the transfer or closure of the account within 60 days of hire. If you have any questions, contact your local Compliance group.
B. Quarterly Reporting and Certification
You must submit a Quarterly Transaction Report to Compliance no later than 30 calendar days after the end of each calendar quarter, or in accordance with regulatory requirements applicable to your region. The Quarterly Report must contain the information set forth below.
For transactions in an Employee Security Account during the previous quarter you must provide:
∙the date of the transaction, the title, and, as applicable, the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares and principal amount of any Covered Security;
∙the nature of the transaction (i.e. purchase, sale or other type of acquisition or disposition);
∙the price of the security at which the transaction was effected;
∙the name of the broker-dealer or bank with or through which the transaction was effected; and
∙the date you submitted the Quarterly Report.
You do not have to submit a Quarterly Transaction Report if it would duplicate information provided in broker trade confirmations or account statements that Compliance already receives or may access.
For any new account established by you during the previous quarter in which any securities are held for your direct or indirect benefit, you must provide:
∙the name of the broker-dealer, bank or financial institution with which you established the account;
∙the date the account was established; and
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∙the date you submitted the Quarterly Transaction Report.
A reminder to complete the Quarterly Transaction Report will be provided to you by Compliance.
C. Annual Reporting and Certification
You must update, as applicable, and certify to the following information on an annual basis (the "Annual Report"):
a list of your current Morgan Stanley brokerage account(s);
a list of all securities and principal amount beneficially owned by you in these account(s);
a list of all your approved Outside Activities, including non-Morgan Stanley brokerage accounts, Private Investments and Outside Activities;
a list of all other investments you hold outside of Morgan Stanley (such as DRIPs, other 401(k) accounts and any securities held in certificate form);
a list of broker-dealers, banks or financial institutions with which you maintain an account in which any securities are held; and
that you have not made, directly or indirectly, any individual investment decision related to such managed account(s), nor have you directed another person to make such investments without first pre-clearing those transactions in accordance with Section III.
The information in the Annual Report must not be more than 45 calendar days old from the day you submit it to Compliance. You must also certify that you have read and agree to abide by the requirements of the Code and that you are in compliance with the Code.
The link to the Annual Report will be provided to you by Compliance.
Hong Kong Type 9 License Holders are required to submit their holdings annually and semi- annually in October and April each year.
VI. OUTSIDE ACTIVITIES AND PRIVATE INVESTMENTS
A. Approval to Engage in an Outside Activity
You may not engage in any Outside Activity, regardless of whether or not you receive compensation or are asked to engage in such activity by the Firm, without prior approval from Compliance. If you receive approval, it is your responsibility to notify Compliance immediately if any conflict or potential conflict of interest arises in the course of the Outside Activity or if the nature of the activity changes, materially. In addition, and as part
17
of the Annual Certification of Employees, you are required to review/edit each disclosure for completeness and accuracy.
Examples of an Outside Activity include providing consulting services, organizing a company, giving a formal lecture or publishing a book or article, accepting compensation from any person or organization other than the Firm, serving as an officer, employee, director, partner, member, or advisory board member of a company or organization not affiliated with the Firm, whether or not related to the financial services industry (including charitable organizations or activities for which you do not receive compensation), setting up a holding company for investments or investing in rental properties. For U.S. registered Employees only, real estate investments that generate rental income require disclosure in the OBI System, unless the propertyis also used by the Employee as a primary, secondary or vacation residence. Generally, Compliance will not approve any Outside Activity related to the securities or financial services industry other than activities that reflect the interests of the industry as a whole and that are not in competition with those of the Firm.
In the case of employees of Morgan Stanley AIP GP LP ("AIP"), where serving on an advisory board for a company in which AIP invests is part of the AIP employee's roles and responsibilities as an employee of AIP, such service shall not be considered an Outside Activity and approval via the OBI System is not required. The relevant senior business managers are responsible for approving Employees to serve on advisory boards, documenting such approvals, maintaining a list of such Employees, and reviewing the list in consultation with the relevant Compliance officers at least annually.
A request to serve on the board of any company, particularly the board of a public company, will be granted in very limited instances only. If you receive approval, your directorship may be subject to the implementation of information barrier procedures to isolate you from making investment decisions for Clients concerning the company in question, as applicable.
B. Approval to Invest in a Private Investment
You may not invest in a Private Investment of any kind without prior approval from Compliance. Private Investments include investments in privately held corporations, limited partnerships, tax shelter programs, hedge funds (including those sponsored by Morgan Stanley or its affiliates), and holding companies (i.e. LLC, LP, S-Corp, C-Corp, etc.).
For SG-licensed employees, it is prohibited to conduct (by way of outside activity or private investment) the following non-financial advisory activities:
-Carrying on moneylending business
-Organising, promoting or conducting any casino marketing arrangement
-Being involved in the real estate agency business
-Marketing any investment that is not an investment product
C. Pre-Clearance Process
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You may request pre-clearance of Outside Activities and Private Investments by typing
"OBI" into your intranet browser.
VII. CONSULTANTS AND TEMPORARY WORKERS
Consultants and other temporary workers who fall under the definition of a Covered Person by virtue of their duties and responsibilities with MSIM must adhere to the following:
Initial, quarterly and annual reporting;
Provision of duplicate trade confirmations and account statements to Compliance for transactions in any Covered Security;
Prohibition against participating in any IPOs;
Pre-clearance of Outside Activities and Private Investments.
Certain Consultants or temporary workers may be required to pre-clear all personal securities transactions in Covered Securities. Consultants or temporary workers that are hired for positions lasting more than one year or are otherwise classified as a Covered Person by their assignment contacts/managers or Complinace are required to transfer brokerage accounts to a Morgan Stanley Broker or Firm approved third party broker as applicable to the respective jurisdiction.
VIII. REVIEW, INTERPRETATIONS AND EXCEPTIONS
Compliance is responsible for administering the Code and reviewing your Initial, Quarterly and Annual Reports. Compliance has the authority to make final decisions regarding Code policies and may grant an exception to a policy as long as it determines that no abuse or potential abuse is involved. Exceptions are granted only in rare and unusual circumstances, such as financial hardship. You must contact Compliance with any questions regarding the applicability, meaning or administration of the Code, including requests for an exception, in advance of any contemplated transaction.
IX. ENFORCEMENT AND SANCTIONS
Violations of the Code are reported to the Head of MSIM Compliance and senior management and, on a quarterly basis, to the applicable funds' board of directors. We may issue letters of warning/education or impose sanctions as appropriate, including notifying your manager, issuing a reprimand (orally or in writing), restricting your trading privileges, reducing your discretionary bonus, if any, requiring reversal of a trade made in violation of the Code or other applicable policies, or taking other disciplinary action, including, but not limited to, suspension or termination of your employment. Violations are considered on a cumulative basis. The foregoing sanctions are intended to be guidelines only. Compliance, in its discretion, may recommend alternative actions if deemed warranted by the facts and
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circumstances of each situation. MSIM management, including the Head of MSIM Compliance, is authorized to determine the choice of actions to be taken in specific cases.
Sanctions may vary based on applicable law and regulatory requirements in your jurisdiction.
X.RELATED POLICIES
In addition to this Code, you are also subject to the policies and procedures documented in the Compliance Manual applicable to your region; the Global Employee Trading Investing and Outside Business Activities Policy; the Morgan Stanley Code of Conduct; the Global Confidential and Material Non-Public Information Policy; the Policy on U.S. Political Contributions and Activities; and the IM Global Gifts, Entertainment and Charitable Giving Policy (requirements may vary in non-U.S. offices).
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SCHEDULE A |
|
SECURITIES TRANSACTION MATRIX |
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|
|
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Pre-Clearance |
Reporting |
30 Calendar days |
|
TYPE OF SECURITY |
Required |
Required |
Holding |
|
(via TPC) |
|
Period |
||
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|
|||
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|
Required |
|
Covered Securities |
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Pooled Investment Vehicles: |
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|
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Closed-End Funds |
Yes |
Yes |
Yes |
|
Open-End Mutual Funds advised by |
No |
Yes |
Yes |
|
MSIM |
||||
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|
|
||
Open-End Mutual Funds sub-advised by |
No |
Yes |
Yes |
|
MSIM |
||||
|
|
|
||
Money Market Funds with Stable NAV |
No |
Yes |
No |
|
Unit Investment Trusts |
No |
Yes |
No |
|
Exchange-Traded Funds (ETFs) (other |
Yes |
Yes |
Yes |
|
than Broad-Based ETFs) |
||||
|
|
|
||
Broad-Based ETFs9 |
No |
Yes |
Yes |
|
Exchange-Traded Notes (ETNs) |
Yes |
Yes |
Yes |
|
Hedge Funds |
Yes |
Yes |
Yes |
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Equities: |
|
|
|
|
Morgan Stanley securities10 |
No |
Yes |
Yes |
|
Common Stocks |
Yes |
Yes |
Yes |
|
Listed depository receipts e.g. |
Yes |
Yes |
Yes |
|
ADRs, ADSs, GDRs |
||||
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DRIPs11 |
Yes |
Yes |
Yes |
|
Stock Splits |
No |
Yes |
No |
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Rights |
Yes |
Yes |
Yes |
|
Stock Dividend |
No |
Yes |
No |
|
Warrants (Listed and Exercised) |
Yes |
Yes |
Yes |
|
Preferred Stock |
Yes |
Yes |
Yes |
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Listed Real Estate Investment Trusts |
Yes |
Yes |
Yes |
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(REITs) |
||||
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Initial Public Offerings (equity IPOs) |
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PROHIBITED |
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and Secondary/ Follow on offerings |
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Private Investments in Public Equity |
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PROHIBITED |
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Securities (PIPES) |
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Derivatives: |
|
|
|
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Morgan Stanley (stock options) |
Yes |
Yes |
Yes |
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Common Stock Options |
Yes |
Yes |
Yes |
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Forward Contracts (including currency |
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PROHIBITED |
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forwards) |
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9Employees must refer to a list of Broad-Based ETFs which may be found here .
10Employees may transact in Morgan Stanley securities during designated window periods. In addition, the pre-clearance of transactions in Morgan Stanley securities is required for all Access Persons.
11Automatic purchases for dividend reinvestment plan are not subject to pre-approval requirements.
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Commodities Contracts |
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PROHIBITED |
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OTC warrants or swaps |
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PROHIBITED |
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Futures |
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PROHIBITED |
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Fixed Income Instruments: |
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Fannie Mae |
Yes |
Yes |
Yes |
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Freddie Mac |
Yes |
Yes |
Yes |
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Corporate Bonds |
Yes |
Yes |
Yes |
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Convertible Bonds (converted) |
Yes |
Yes |
Yes |
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Municipal Bonds |
Yes |
Yes |
Yes |
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New Issues (fixed income) |
Yes |
Yes |
Yes |
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High Yield Securities |
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PROHIBITED |
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Private Investments (e.g. limited |
Yes |
Yes |
N/A |
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partnerships) |
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Private Investments and Outside Activities: |
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Private Investments (e.g., limited |
Yes (via OBI) |
Yes |
N/A |
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partnerships) |
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Outside Activities |
Yes (via OBI) |
Yes |
N/A |
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Investment Clubs |
PROHIBITED |
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Exempt Securities: |
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Mutual Funds (open-end) not |
No |
Yes |
No* |
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advised or sub-advised by MSIM |
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(Except for Hong |
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Kong SFC Type 9 |
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US Treasury/Sovereign Debt12 |
No |
Yes |
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licensed employees |
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Brokerage CDs |
No |
Yes |
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as 30 calendar days |
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Money Market Funds |
No |
Yes |
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holding period is |
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GNMA |
No |
Yes |
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required for all |
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Commercial Paper |
No |
Yes |
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personal account |
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Bankers' Acceptances |
No |
Yes |
investments in |
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Investment Grade Short-Term Debt |
No |
Yes |
securities including |
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Instruments13 |
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exempt securities |
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for such |
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employees) |
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12Sovereign debt securities rated AA or higher.
13For these purposes, repurchase agreements and any instrument that has a maturity at issuance of fewer than 366 days that is rated as investment grade by a nationally recognized statistical rating organization.
* Yes: for Hong Kong SFC Type 9 licensed employees as 30 calendar day holding period is required for all personal account investments in securities including exempt securities
22
INVESTMENT MANAGEMENT DIVISION
(Excluding Private Side)
Registered Investment Advisers
Morgan Stanley Investment Management Inc.
Morgan Stanley AIP GP LP
Morgan Stanley Investment Management Limited (MSIM Ltd.)
Morgan Stanley Investment Management Company (Singapore)
Registered Commodity Pool Operator/Commodity Trading Advisor
Ceres Managed Futures LLC
Investment Advisers that are not registered
Morgan Stanley Investment Management Private Limited (MSIM Private Limited) (with respect to Public Side Investment Management Employees only)
Morgan Stanley Investment Management (Australia) Pty Limited
Morgan Stanley Asia Limited (MSAL) (with respect to Public Side Investment Management Employees only)
Morgan Stanley Investment Management (Japan) Co., Ltd. (MSIMJ)
Private Investment Partners, Inc.
Broker-Dealer
Morgan Stanley Distribution Inc.
Transfer Agent
Morgan Stanley Services Company Inc.
Global In-house Centers (India)
Morgan Stanley Advantage Services Pvt. Ltd. (with respect to Public Side Investment Management Employees only)
Morgan Stanley Solutions India Pvt. Ltd. (with respect to Investment Management Public Side Employees only)
Others:
MSIP Seoul Branch ("MSK") (with respect to Public Side Investment Management Employees only)
23
Nuveen Compliance | 26 August 2019
Code of Ethics
SUMMARY AND SCOPE
What the Code is about
Helping to ensure that Nuveen personnel place the interests of Nuveen clients ahead of their own personal interests.
Who the Code applies to and what the implications are
This Code applies to individuals in the following categories:
•Nuveen Employees based in the US or Canada (except employees of Gresham Investment Management LLC, Westchester Group Investment Management, Inc., andany employees of Greenwood Resources, Inc. who are based outside of Portland, Oregon).
•Employees of any US-registered investment adviser who are based outside the US, except Gresham Investment Management LLC and Greenwood Resources, Inc.
•Consultants, interns, and temporary workers based in the US or Canada whose contract length is 90 days or more, unless the Nuveen Ethics Office determinesotherwise.
•Any TIAA employees designated as Access Persons by the TIAA-CREF Funds Chief Compliance Officer or the Nuveen Ethics Office.
Independent directors and trustees of the TIAA-CREF Funds Complex and Nuveen-sponsored or -branded funds have their own Code of Ethics and are not subject to this one.
For individuals who are subject to the Code, there are two designations with different implications: Access Person and Investment Person.
ACCESS PERSON
All Nuveen Employees who are subject to the Code are considered Access Persons, since they have, or could have, access to non-public information about securities transactions and other investments, holdings, or recommendations for Affiliate-Advised Accounts or Portfolios.
Key characteristics of this designation. An individual may be considered an Access Person of multiple advisers affiliated with Nuveen, or of only one. If your regular duties give you access to non-public information, or you are an officer of a Nuveen or TIAA-CREF sponsored or branded fund, your personal trading is generally monitored only against the trading activity of the specific adviser(s) or Affiliated Funds
with which you are involved. For other employees, personal trading is typically monitored against the trading activities of all advisers affiliated with Nuveen. You will generally not be permitted to execute transactions in a security on any day when an Affiliate-Advised Account or Portfolio managed by the adviser(s) that you are monitored against has a pending buy or sell order for that security.
INVESTMENT PERSON
An Access Person who meets any of the following criteria will in addition be considered an Investment Person:
•The Access Person is a Portfolio Manager, Research Analyst or Research Assistant, or they otherwise participate in making recommendations or decisions concerning the purchase or sale of securities in any Affiliate-Advised Account or Portfolio.
•The Access Person has been designated an Investment Person by the Nuveen Ethics Office.
Key characteristics of this designation. The vast majority of Investment Persons are employees of Nuveen's affiliated investment advisers.
An Investment Person is prohibited from transacting in securities during the period starting 7 calendar days before, and ending 7 calendar days after, any trade in an Affiliate-Advised Account or Portfolio for which he/she has responsibility. In addition, an Investment Person's personal transactions will be reviewed for conflicts in the period starting 7 calendar days before, and ending 7 calendar days after, all trades by their associated investment adviser. In some cases, the Investment Person may be required to reverse a trade and/or forfeit an appropriate portion of any profit as determined by the Nuveen Ethics Office. These consequences can apply whether or not the trade was pre-cleared.
The personal trading of Investment Persons is generally only monitored against the trading activity of the specific adviser for which they have been designated an Investment Person.
Code of Ethics |
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Important to understand
Some of our affiliated investment advisers may have policies of their own that impose additional rules on the same topics covered in this Code. Check with your manager or local/designated Chief Compliance Officer (CCO) if you have questions.
Personal trading is a privilege, not a right. Nuveen Employees are expected to follow the law and adhere to the highest standards of behaviorincluding with respect to personal trading. Any violation of the Code could have severe adverse effects on you, your co-workers, and Nuveen. You may be held personally liable for your conduct and be subject to fines, regulatory sanctions, and even criminal penalties. Because Nuveen can restrict your trading or take actions such as forcing you to hold a position or to disgorge profits, personal trading carries risks beyond normal market risks.
Some requirements in this Code apply to Household Members. Each Household Member (see "Terms with Special Meanings" at right) is subject to the same restrictions and requirements that apply to his/her related Nuveen Employee.
The Code does not address every ethical issue that might arise. If you have any doubt at all after consulting the Code, contact the Nuveen Ethics Office for direction.
The Code applies to appearance as well as substance. Always consider how any action might appear to an outside observer (such as a client or regulator).
You are expected to follow the Code both in letter and in spirit. Literal compliance, such as pre-clearing a transaction, does not necessarily protect you from liability for conduct that violates the spirit of the Code. If you have questions about how to comply with this Code, consult the Nuveen Ethics Office.
WHO TO CONTACT
Nuveen Ethics Office (Americas)
Hotline: 1-800-842-2733 extension 22-5599 nuveenethicsoffice@nuveen.com
TERMS WITH SPECIAL MEANINGS
Within this policy, these terms are defined as follows:
Affiliate-Advised Account or Portfolio Any Affiliated Fund, or any portfolio or client account advised or sub-advised by Nuveen.
Affiliated Fund Any TIAA-CREF or Nuveen branded or sponsored open-end fund, closed-end fund, or Exchange Traded Fund (ETF), and any third-party fund advised or sub-advised by Nuveen.
Automatic Investment Plan Any program, such as a dividend reinvestment plan (DRIP), under which investment account purchases or withdrawals occur according to a predetermined schedule and allocation.
Beneficial Ownership Any interest by which you or any Household Memberdirectly or indirectlyderives a monetary benefit from purchasing, selling, or owning a security or account, or exercises investment discretion.
You have Beneficial Ownership of securities held in accounts in your own name, or any Household Member's name, and in all other accounts over which you or any Household Member exercises or may exercise investment decision-making powers, or other influence or control, including trust, partnership, estate, and corporate accounts or other joint ownership or pooling arrangements.
Code This Code of Ethics.
Domestic Partner An individual who is neither a relative of or legally married to a Nuveen Employee, but shares a residence and is in a mutual commitment similar to marriage with such Nuveen Employee.
Federal Securities Laws The applicable portions of any of the following laws, as amended, and of any rules adopted under them by the Securities and Exchange Commission or the Department of the Treasury:
•Securities Act of 1933.
•Securities Exchange Act of 1934.
•Investment Company Act of 1940.
•Investment Advisers Act of 1940.
•Sarbanes-Oxley Act of 2002.
•Title V of the Gramm-Leach-Bliley Act.
•The Bank Secrecy Act.
Household Member Any of the following who reside, or are expected to reside for at least 90 days a year, in the same household as a Nuveen Employee:
•Spouse or DomesticPartner. • Parent, stepparent,
• Sibling. |
grandparent. |
•Child, stepchild, grandchild. • In-laws, (mother, father, son, daughter,
brother, sister).
Independent Director Any director or trustee of an Affiliated Fund who is not an "interested person" within the meaning of Section 2(a)(19) of the Investment Company Act of 1940, as amended.
Managed Account Any account, including robo- advised accounts, in which you or a Household Member has Beneficial Ownership and for which you have delegated full investment discretion in writing to a third- party broker or investment manager.
Code of EthicsPage 3 of 8
TERMS WITH SPECIAL MEANINGS (continued)
Nuveen Nuveen, LLC and all of its direct or indirect |
Reportable Security Any security EXCEPT: |
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subsidiaries worldwide. |
• Direct obligations of the US government (indirect |
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Nuveen Employee Any full- or part-time employee of |
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obligations, such as Fannie Mae and Freddie Mac |
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Nuveen, and any consultants, interns or temporary workers |
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securities, are reportable). |
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designated by the Nuveen Ethics Office. |
• Certificates of deposit, bankers' acceptances, commercial |
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Private Placement Any offering exempt from registration |
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paper, and high quality short-term debt (including |
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under the Securities Act of 1933, such as a private equity |
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repurchase agreements). |
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investment, hedge fund, or limited partnership. |
• |
Money market funds. |
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Reportable Account Any account for which you or a |
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• |
Open-end funds that are not Affiliated Funds. |
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Household Member has Beneficial Ownership AND in which |
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Note that closed-end funds are Reportable Securities. |
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securities can be bought or held. This includes, among others: |
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Reportable Transaction Any transaction involving a |
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• All Managed Accounts. |
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Reportable Security EXCEPT: |
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• Any Nuveen 401(k) plan account. |
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• Transactions in Managed Accounts. Section 16 Persons: |
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• Any 401(k) plan account from a previous employer that |
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Transactions involving Nuveen closed-end funds in any of |
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permits transactions in any Reportable Security. |
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your Managed Accounts are reportable. |
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• Any direct holding in an Affiliated Fund. |
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• Transactions under an Automatic Investment Plan; note |
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• Any retirement account or health savings account (HSA) |
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that transactions that override the pre-set schedule or |
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that permits the purchase of any Reportable Security, and |
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allocation are reportable. |
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any 529 college savings plan that permits the purchase of |
Section 16 Person Section 16 of the Exchange Act and |
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Affiliated Funds. |
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the rules thereunder impose certain obligations on persons |
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The following are NOT considered Reportable Accounts: |
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specified in section 30(h) of the Investment Company Act of |
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• Charitable giving accounts. |
1940, as well as insiders of any public company that trades |
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• Any 401(k) plan account or any other account held |
on a national stock exchange (such as a Nuveen closed-end |
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fund). For purposes of Section 16, an "insider" is: |
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directly with a mutual fund complex or mutual fund-only |
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• A director of a public company. |
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platform in which open-end, non-Affiliated Funds are the |
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only possible investment. |
• A designated officer of a public company. |
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• Any cash management account with a broker in which a |
• A person who beneficially owns 10% or more of any class |
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Reportable Security cannot be purchased or sold. |
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of equity security that is registered under Section 12 of |
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• Any accounts that can invest only in non-Reportable |
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the Exchange Act. |
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Securities, such as cryptocurrencies or US |
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• A portfolio manager of a Nuveen closed-end fund. |
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Treasury securities. |
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Persons subject to Section 16 include portfolio managers of |
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the Nuveen closed-end funds. |
GENERAL RESTRICTIONS AND REQUIREMENTS
BASIC PRINCIPLES
1.Never abuse a client's trust, rights, or interests. This means you must never do any of the following:
•Engage in any plan or action, or use any device, that would defraud or deceive a client.
•Make any material statements of fact that are incorrect or misleading, either as to what they include or omit.
•Engage in any manipulative practice.
•Use your position (including any knowledge or access to opportunities you have gained by virtueof your position) to personal advantage or to a client's disadvantage. This would include, for example, front-running or tailgating (trading directly before or after the execution of a large client trade order), or any attempt to influence a client's trading to enhance the value of your personal holdings.
•Conduct personal trading in any way that could be inconsistent with your fiduciary duties to a client (even if it does not technically violate theCode).
2.Handle conflicts of interest appropriately. This applies not only to actual conflicts of interest, but also to any situation that might appear to an outside observer to be improper or a breach of fiduciary duty.
3.Keep confidential information confidential. Always properly safeguard any confidential information you obtain in the course of your work. This includes confidential information related to any of the following:
•Any Affiliate-Advised Account or Portfolio and any other financial product offered or serviced by Nuveen.
•New products, product changes, or business initiatives.
Code of Ethics |
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•Past, current, and prospective clients, including their identities, investments, and account activity.
"Keeping information confidential" means using discretion in disclosing information as well as guarding against unlawful or inappropriate access by others. This includes:
•Making sure no confidential information is visible on your computer screen and desk when you are not there.
•Not sharing passwords with others.
•Using caution when discussing business in any location where your conversation could beoverheard. Confidential information may be released only as required by law or as permitted under the applicable privacy policy(ies). Consult the Nuveen Ethics Office or your local/designated CCO before releasing any confidential information.
4.Handle Material Non-Public Information properly. Follow all of the terms described in "Material Non-Public Information" below. Be aware that any failure to handle such information properly is a serious offense and may lead to disciplinary action from Nuveen as well as serious civil or criminal liability.
5.Comply with Federal Securities Laws. Any violation of these laws is punishable as a violation of the Code.
6.Never do anything indirectly that, if done directly, would violate the Code. Such actions will be considered the equivalent of direct Code violations.
7.Promptly alert the Nuveen Ethics Office or your local/designated CCO of any actual or suspected wrongdoing. Examples of wrongdoing include violations of the Federal Securities Laws, misuse of corporate assets, misuse of confidential information, or other violations of the Code. If you prefer to report confidentially, call the TIAA Confidential Helpline at 1-877-774-6492. Note that failure to report suspected wrongdoing in a timely fashion is itself a violation of the Code.
PRE-CLEARANCE AND
HOLDING REQUIREMENTS
8.Pre-clear any trade in Reportable Securities, including certain Affiliated Funds (see box on next page for additional information).
If your trade requires pre-clearance, request approval through the Protegent PTA system (PTA) before you or any Household Member places an order to buy or sell any Reportable Security. Any approval you receive expires at the end of the day it was granted; however, you may place after-hours trades in international markets until 11:59 PM local time on that day. When requesting pre-clearance, follow this process:
•Request pre-clearance on the same day you want to trade, during standard US trading hours (9:30 AM to 4:00 PM ET). Be sure your pre-clearance request is accurate as to security and direction of trade.
•Wait for approval to be displayed before trading. If you receive approval, you may only trade that same day, and only within the scope of approval. If you do not receive approval, do not trade.
•Place day orders only. Do not place good-til-canceled orders. You may place orders for an after-hours trading session or in foreign markets using that day's pre-clearance approval, but you must not place any order that could remain open into the next day's trading session.
9.Hold positions in securities that are subject to pre-clearance for 60 calendar days, or be prepared to forfeit any gains. Several things to note:
•You may be required to surrender any gains realized (net of commissions) through a violation of this rule.
•The 60-day holding requirement is tested on a last- in-first-out basis, across all of your holdings (not just within individual accounts).
•The 60-day holding requirement extends to any options or other transactions that may have the same effect as a purchase or sale, and to all Reportable Securities except Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs), Unit Investment Trusts (UITs), and open-end Affiliated Funds. Nuveen-branded or sponsored closed-end funds are subject to the 60-day holding requirement.
•You may sell the security on the 60th day after purchase, provided you obtain pre-clearance or an exemption applies.
•You may re-purchase a security immediately after executing a sale of that same security, which will trigger a new 60 calendar day holding period.
•You may close a position at a loss at any time, provided pre-clearance has been obtained or an exemption applies.
10.Comply with trading restrictions described in the prospectuses for all Affiliated Funds. This includes restrictions on frequent trading in shares of any open-end Affiliated Fund.
11.Pre-clear any transaction in a Managed Account that involves your influence. You must also immediately consult with the Nuveen Ethics Office to discuss whether the account in question can properly remain classified as a Managed Account.
Code of Ethics |
Page 5 of 8 |
12.Obtain the required approvals before any transaction in a Private Placement. For any private funds advised or sub-advised by Nuveen, you must obtain approval for all transactions (initial investment, subsequent investment, sales/redemptions) except additional capital calls. For all other Private Placements, you must obtain approval for initial and subsequent investments but not sales/redemptions. Approval is required even if the investment is made in a Managed Account.
WHAT NEEDS TO BE PRE-CLEARED
Pre-clearance required
•All actively initiated trades in Reportable
Securities, except those listed here under "No pre- clearance required."
•Restricted stock or employee stock options accrued during prior employment or a Household Member's employment require pre-clearance. If pre-clearance is denied, you may contact the Nuveen Ethics Office to request reconsideration.
Be aware that pre-clearance can be withdrawn even after it has been granted, and even after you have traded, if Nuveen later becomes aware of Affiliate-Advised Account or Portfolio trades whose existence would have resulted in denial of pre-clearance. In these cases you may be required to reverse a trade and/or forfeit an appropriate portion of any profit, as determined by the Nuveen Ethics Office.
Pre-clearance not required
•Shares of any open-end mutual fund (including Affiliated Funds).
•ETFs, ETNs, UITs.
•CDs and commercial paper.
•Securities acquired or disposed of through actions outside your control or issued pro rata to all holders of the same class of investment, such as automatic dividend reinvestments, stock splits, mergers, spin-offs, or rights subscriptions.
•Sales pursuant to a bona fide tender offer.
•Trades made through an Automatic Investment Plan that has been disclosed to the Nuveen Ethics Office in advance.
•Trades in a Managed Account (except that you must pre-clear any trades that involve your influence, any initial purchases of private placements, purchases in any equity IPO, and any sales or redemptions of private placements that are branded, sponsored, advised or sub- advised by Nuveen).
•Foreign currencies, including futures.
•Commodity instruments.
•Index options and index futures.
•Direct investments in cryptocurrencies.
OTHER RESTRICTIONS
13.Never knowingly trade any security being traded or considered for trade by any Affiliate-Advised Account or Portfolio. This applies to employee transactions in securities that are exempt from pre- clearance, and includes equivalent or related securities.
For example, if a company's common stock is being traded, you may face restrictions on trading any of the company's debt, preferred, or foreign equivalent securities, and from trading or exercising any options based on the company's securities.
14.Always prioritize client trades over personal trades. Your fiduciary duties to the client are far more important than your personal trading, which is a privilege and not a right. Never delay or in any way alter the timing or terms of a client trade for your personal benefit.
15.Do not engage in trading that involves single stock futures, uncovered short sales or uncovered options on individual securities. For any short position you must own the underlying security in equal notional value. Options are permitted only to generate income or for hedging (that is, selling calls or writing puts that are offset by existing long positions), with the following exceptions:
•You may buy or sell (write) uncovered long-term options (those with an expiration of 1 year or more from the date of purchase), subject to the 60-day holding period.
•Hedging with puts or with shorts against the box is permitted, however, unless the transaction is a covered call (which can be written when you acquire the underlying position), you must first hold the underlying position for 60 days.
16.Never participate in an investment club or similar entity.
17.Do not engage in excessive or inappropriate trading activity. Never let personal trading interfere with your professional duties. The Nuveen Ethics Office and/or your local/designated CCO, in consultation with your manager, will determine what constitutes excessive or inappropriate trading.
18.Pre-clear the sale of securities in a margin account. Margin accounts are permitted, however you must obtain pre-clearance when selling to meet a margin call, even if the transaction is initiated by a broker.
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19.Never purchase an IPO without advance approval. This includes Managed Accounts. Equity IPO participation is generally prohibited, but approval may be granted in special circumstances, such as when:
•You already have equity in the company and are offered shares.
•You are a policy holder or depositor in a company that is demutualizing.
•A family member has been offered shares as an employee.
Purchases of initial offerings of fixed income securities, convertible securities, preferred securities, open- and closed-end funds, commodity pools, and secondary equity offerings are generally permitted subject to prior approval from the Nuveen Ethics Office.
MATERIAL NON-PUBLIC INFORMATION
What is Material Non-Public Information?
Material Non-Public Information is defined as information regarding any security, securities-based derivatives or issuer of a security that is both material and non-public. Information is material if both of the following are true:
•A reasonable investor would likely consider it important when making an investment decision.
•Public release of the information would likely affect the price of a security.
Information is generally non-public if it has not been distributed through a widely used public medium, such as a press release or a report, filing or other periodic communication.
Restrictions and requirements
•Any time you think you might have, or may be about to, come into possession of Material Non-Public Information (whether in connection with your position at Nuveen or not), alert the Nuveen Ethics Office. Alternatively, you may alert your local/designated CCO or Legal office, who in turn must promptly notify the Nuveen Ethics Office. Follow the instructions you are given.
REPORTING REQUIREMENTS
•Until you receive further instructions from the Nuveen Ethics Office, your local/designated CCO, or Legal, do not take any action in relation to the information, including trading or recommending the relevant securities or communicating the information to anyone else.
•Never make decisions on your own regarding potential Material Non-Public Information, including whether such information is actually Material Non-Public Information or what steps should be taken.
•If the Nuveen Ethics Office, your local/designated CCO and/or Legal determine that you have Material Non- Public Information:
Do not buy, sell, gift, or otherwise dispose of the issuer's securities, whether on behalf of an Affiliate-Advised Account or Portfolio, yourself, or anyone else.
Do not in any way recommend, encourage, or influence others to transact in the issuer's securities, even if you do not specifically disclose or reference the Material Non- Public Information.
Do not communicate the Material Non-Public Information to anyone, whether inside or outside Nuveen, except in discussions with the Nuveen Ethics Office and Legal and as expressly permitted by any confidentiality agreement or supplemental policies and procedures of your business unit.
UPON BECOMING A NUVEEN EMPLOYEE
20.Within 10 calendar days of starting at Nuveen, acknowledge receipt of the Code. This includes certifying that you have read the Code, understand it, recognize that you are subject to it, have complied with all of its applicable requirements, and have submitted all Code-required reports.
21.Within 10 calendar days of starting at Nuveen, use PTA to report all of your Reportable Accounts and holdings in Reportable Securities.
For each Reportable Account, upload the most recent statement, making sure that it includes information about the broker, dealer, or bank through which the account is held and the type of account.
For each Reportable Security, provide the security name and type, a ticker symbol or CUSIP, the number of shares or units held, and the principal amount (dollar value). This information must be no older than 45 calendar days before your first day of employment.
Note that there are separate procedures for Managed Accounts, as described below in item 24. Within 10 calendar days of starting at Nuveen, report all current investments in private placements (limited offerings). Limited offerings are Reportable Securities.
22.Within 30 calendar days of starting at Nuveen, move or close any Reportable Account that is not at an approved firm. This does not include Reportable Accounts that are 401(k), HSA, or 529 accounts. Contact the Nuveen Ethics Office if you are unsure whether your
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account must be held with an approved firm. The list of approved firms is maintained by the Nuveen Ethics Office and may be accessed on PTA.
Under very limited circumstances, it may be possible to obtain a waiver to keep a Reportable Account at a non- approved firm. Examples include:
•An account owned by a Household Member who works at another financial firm with comparable restrictions.
•An account that holds securities that cannot be transferred.
•An account that cannot be moved because of a trust agreement.
To apply for an exception, contact the Nuveen Ethics Office. For any account granted an exception, arrange for the Nuveen Ethics Office to receive duplicates of all periodic statements. If a firm cannot provide duplicate statements directly to the Nuveen Ethics Office, you must take responsibility for providing them yourself. In all cases, if your accounts are not held at an approved firm, you must manually enter all executed transactions in PTA within 5 days of execution.
At the discretion of the Nuveen Ethics Office, some consultants and temporary workers may not be required to move or close Reportable Accounts.
EVERY QUARTER
25.Within 30 calendar days of the end of each calendar quarter, verify in PTA that all Reportable Transactions made during that quarter have been reported. PTA will display all transactions of yours for which it has received notice (except transactions in your TIAA pension or and retirement plan accounts, which you are not required to report because the firm accesses this informaiton directly). For any other Reportable Transactions not displayed, or displayed inaccurately, you are responsible for making any necessary revisions in PTA to complete your certification.
26.For each Reportable Transaction, you must provide, as applicable, the transaction date, security nameand type, ticker symbol or CUSIP, interest rate (coupon) and maturity date, number of shares, price at which the transaction was effected, principal amount (dollar value), the nature of the trade (buy or sell), and the name of the broker, dealer, or bank that effected the transaction. It is very important that you carefully review and verify the transactions and related details displayed on PTA, checking for accuracy and completeness. Once again, if you find any errors or omissions, correct or add to your list of transactions in PTA.
WHEN OPENING ANY NEW REPORTABLE ACCOUNT (INCLUDING A MANAGED ACCOUNT)
23.Get pre-approval for any new Managed Account before any trading activity commences. Using the appropriate form (available from the Nuveen Ethics Office), provide representations that support the classification of the account as a Managed Account. For an account to be classified as a Managed Account, the account owner must have no direct or indirect influence or control over the securities in the account. The form must be signed by the account's broker or investment manager and by all account owners. You may be asked periodically to confirm these representations.
Note that if the Managed Account is not maintained at an approved firm, you are also responsible for providing duplicate statements for the Managed Account to the Ethics Office, if requested.
24.Report any new Reportable Account (other than a Managed Account) that is opened with an approved firm. Do this within 10 calendar days of the date you or a Household Member opens the account or an account becomes a Reportable Account through marriage, cohabitation, divorce, death, or another event.
EVERY YEAR
27.Within 45 calendar days of the end of each calendar year, acknowledge receipt of the most recent version of the Code and certify in PTA as to your Annual Holdings and Accounts Report.
The report must contain the information described in item 20 above, and include your certification that you have reported all Reportable Accounts, and all holdings in Reportable Securities at year end.
If any of your holdings in Reportable Securities are not displayed in PTA or are displayed inaccurately, you are responsible for making any necessary revisions in PTA to complete your certification.
In addition, you must affirm each year through PTA that each Managed Account is properly classified as a Managed Account, for yourself and on behalf of any Household Member. This separate certification does not require broker or investment manager involvement.
You also must acknowledge any amendments to the Code that occur during the course of the year.
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ADDITIONAL RULES FOR
SECTION 16 PERSONS
•Pre-clear (through PTA) any transactions in Nuveen closed-end funds and any other closed-end funds of which you are a Section 16 Person. Your request will be reviewed by Legal.
•Pre-clear buy/sell transactions involving any Nuveen closed-end funds within your Managed Account(s).
•When selling for a gain any securities you buy that are issued by the entity of which you are a Section 16 Person, make sure it is at least 6 months after your most recent purchase of that security. This rule extends to any options or other transactions that may have the same effect as a purchase or sale, and is tested on a last-in- first-out basis. You may be required to surrender any gains realized through a violation of this rule. Note that for any fund of which you are a Section 16 Person, no exception from pre-clearance is available.
•Promptly email details of all executed transactions in these securities to the appropriate contact in Legal.
•See the Nuveen Funds Section 16 Policy and Procedures for additional information.
If you are unsure whether you are a Section 16 Person, contact Legal or the Nuveen Ethics Office.
CODE ADMINISTRATION
Training
You will be required to participate in training on the Code when joining Nuveen as well as periodically during the time you are subject to the Code.
Exceptions
The Code exists to prevent violations of law. The Nuveen Ethics Office may, under certain circumstances, grant waivers from a Code requirement. No waivers or exceptions that would violate any law will be granted.
Monitoring
The Nuveen Ethics Office is responsible for monitoring transactions and holdings for any violations of this Code.
Consequences of violation
Any individual who violates the Code is subject to penalty. Penalties could include, among other possibilities, a written warning, restriction of trading privileges, disgorgement
of trading profits, fines, and suspension or termination of employment.
Applicable rules
The Code has been adopted in recognition of Nuveen's fiduciary obligations to clients and in accordance with various provisions of Rule 204A-1 under the Investment Advisers Act of 1940 and Rule 17j-1 under the Investment Company Act of 1940. This Code is also adopted by the Affiliated Funds advised by Nuveen Fund Advisors, LLC, TIAA-CREF Investment Management, LLC and Teachers Advisors, LLC under Rule 17j-1.
Some elements of the Code also constitute part of Nuveen's response to Financial Industry Regulatory Authority (FINRA) requirements that apply to registered personnel of Nuveen Securities, LLC.
Code of Ethics
Scout Investments
Reams Asset Management Division
August 2019
I. GENERAL PROVISIONS
This Code of Ethics has been adopted by Scout Investments ("SI"), including its Reams Asset Management Division ("Reams"), with the objectives of deterring wrongdoing and (1) providing standards of honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, (2) promoting full, fair, accurate, timely and understandable disclosure in reports and documents which the Firm files with the Securities and Exchange Commission and in other public communications made by Scout, (3) promoting compliance with applicable governmental laws, rules and regulations, (4) facilitating prompt internal reporting of violations of this Code of Ethics, and (5) providing accountability for adherence to this Code of Ethics.
This Code of Ethics applies to all Supervised Persons. A Supervised Person means any Scout employee who provides advice on behalf of Scout and who are subject to Scout's supervision and control.
All Supervised Persons have a duty and requirement to:
∙Place the clients' interests first;
∙Conduct all personal transactions in accordance with this Code of Ethics and in compliance with applicable laws and regulations;
∙Avoid actual or potential conflicts of interest (or when this is not possible, fully disclose them to the client) or any abuse of their position of trust and responsibility and not take inappropriate advantage of their position;
∙Maintain the confidentiality of the identity of security holdings and financial circumstances of clients;
∙Maintain their independence in the investment decision-making process applicable to the degree they participate in the investment decision-making process;
∙Comply with applicable federal securities laws; and
∙Report any violations of this code to the Chief Compliance Officer.
Implementation and interpretation of this Code are the primary responsibilities of the Chief Compliance Officer. In administering these responsibilities, the Chief Compliance Officer may consult with Scout management as appropriate regarding violations of the Code and in applying penalties as identified on Appendix A Schedule of Sanctions. Any alleged violations of this Code must be reported to the Chief Compliance Officer. Scout may take disciplinary action and/or impose sanctions including, but not limited to, termination of employment, suspension, revocation of personal trading privileges and/or disgorgement of profits resulting from the violation. Financial penalties for noncompliance will be contributed to a charitable foundation or to a charity. Additional consequences for noncompliance and actions are not limited to the penalties listed depending upon the circumstances of noncompliance. Furthermore, violations of the Code of Ethics may also be violations of the law and may result in civil and/or criminal penalties.
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The Chief Compliance Officer will take reasonable means to protect the privacy of personal information collected in implementing the Code of Ethics. If a violation occurs or a matter is in need of resolution, only the minimum information as determined by the Chief Compliance Officer will be disclosed as needed to communicate or facilitate consideration with appropriate individuals of any matter under this Code of Ethics. Information may also be disclosed to the extent necessary to implement and enforce the provisions of this Code of Ethics or to respond to appropriate requests.
II. STANDARDS OF BUSINESS CONDUCT
Conflicts of Interest
All Supervised Persons have an affirmative duty of care, loyalty, honesty, and good faith, and to act in the best interests of their clients. Compliance with this duty is best served by avoiding conflicts of interest and by fully disclosing all material facts concerning any conflict that does arise with respect to any client. A "conflict of interest" occurs when an individual's personal interests interfere or appear to interfere with client interests. A conflict may arise when a person takes actions or has interests that make it difficult to perform his or her duties with respect to the client objectively and effectively. Conflicts of interest may also arise when a person receives improper benefits, or members of his or her family receive improper personal benefits resulting from his or her position.
Supervised Persons must avoid conduct or activities that may appear to be a conflict or impropriety. Any Supervised Person that feels a need to disclose a potential conflict should first discuss the potential conflict with his/her supervisor and/or the Chief Compliance Officer.
Conflicts Among Client Interests
Supervised Persons should not favor the interests of one client over another client. Inappropriate favoritism of one client over another client constitutes a breach of fiduciary duty.
Competing with Client Trades
Supervised Persons are prohibited from competing with client securities transactions by profiting personally, directly or indirectly, from personal securities trades by using knowledge about pending or potential securities transactions of clients.
Disclosure of Personal Interest
Supervised Persons are prohibited from recommending, implementing or considering any securities transaction for a client without having disclosed any material beneficial ownership, business or personal relationship, or other material interest in an issuer or its affiliates, to the Chief Compliance Officer. For purposes of this paragraph, material beneficial ownership is an investment in an amount that could potentially alter judgment regarding the security and, at a minimum, is defined as the Supervised Person having beneficial ownership of 1% or more of any class of common equity securities of the subject company. If the beneficial ownership is concluded to present a material conflict, the Supervised Person may not participate in any decision-making process regarding the securities of that issuer. Research analysts with a material personal interest in an issuer are precluded from covering that issuer. If the Supervised Person has any doubts as to whether a material interest, beneficial ownership or relationship could potentially impair their judgment, then the Supervised Person should contact the Chief
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Compliance Officer to discuss details of the holding, relationship or activity. The Chief Compliance Officer will consult with the appropriate portfolio manager as necessary or legal counsel in rendering a decision and notify appropriate parties of the material personal interests identified.
Vendors and Suppliers
Supervised Persons must disclose personal investments or other interests in vendors or suppliers with respect to which the Supervised Person negotiates or makes decisions regarding the selection of that vendor or supplier for services provided to clients. The Supervised Person must disclose this interest to the Chief Compliance Officer. If the Chief Compliance Officer determines the beneficial ownership presents a material conflict, the Supervised Person may not participate in any decision-making process regarding procurement of the services of that vendor or supplier for clients.
Transactions with Clients
Supervised Persons are prohibited from knowingly purchasing from or selling to a client any security or other property, except securities issued by the client.
III. INSIDER TRADING
Insider trading involves the purchase or sale of securities of a company or other entity while in possession of material, nonpublic information (also called "inside information") about the company or entity. Any Supervised Person who purchases or sells securities while in possession of material inside information or who communicates or "tips" such inside information to anyone else who trades securities on such information, violates this Code of Ethics and may violate United States securities laws. Federal law imposes obligations on employers to ensure that their employees do not improperly trade securities using inside information. Any Supervised Person who becomes aware of material nonpublic information should not, without first discussing the information with the Chief Compliance Officer:
Trade in the securities of such company for a personal or client's account;
Recommend transactions in the security; or
Disclose (tip) the information to others.
Scout's Insider Trading Policies and Procedures (Insider Trading Policy) is included for detailed policies and procedures governing insider trading. The Insider Trading Policy is incorporated as part of this Code of Ethics and for purposes of applying this Code's provisions.
IV. GIFTS AND ENTERTAINMENT
Giving or Receiving Gifts or Entertainment
Supervised Persons should exercise good judgment in providing or accepting anything of value. Supervised Persons shall not offer, provide or solicit for themselves, or any third party, anything of value from anyone in return for any business, service, or confidential or proprietary information. Furthermore, Supervised Persons are prohibited from providing or accepting anything of value from anyone as a condition of obtaining the business of Scout or any of their subsidiary or affiliated companies, either before or after the transaction is discussed or consummated. Gifts or entertainment should never be provided or accepted in circumstances in
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which it appears to others that business judgment has been compromised. This does not prohibit associates and officers from providing or accepting something of nominal value from a customer or supplier doing or seeking to do business with Scout without the risk of corruption or breach of trust. Cash and checks, however, should not be accepted regardless of amount. The following examples help explain what is permissible under the policy:
∙Receipt of gifts from any one Investment Related Entity not to exceed $100 per year (on an individual employee basis);
∙Receipt of entertainment from any one Investment Related Entity not to exceed $100 per event and $250 per year (on an individual employee basis);
∙The provision or acceptance of gifts, gratuities, amenities, or favors based on obvious family or personal relationships where the circumstances make it clear that those relationships are the motivating factor;
∙The provision or acceptance of meals, refreshments, entertainment or transportation to local events, all of reasonable value and in the course of business at which the giver is present. (Acceptance of accommodations or non-local travel arrangements should not be accepted). Examples include an occasional meal, a ticket to a sporting event or the theater, or comparable entertainment which is neither so frequent nor so extensive as to raise any question of propriety. The acceptance of advertising or promotional material of reasonable value such as pens, pencils, notepads, key chains, calendars and similar items;
∙The acceptance of discounts or rebates on merchandise or services that do not exceed those available to other customers; or
∙The provision or acceptance of gifts of reasonable value (a real or perceived value of $100 or less) where the gift is neither so frequent nor so extensive as to raise any question of propriety. Entertainment where the giver is not present is considered a gift.
Reporting Gifts or Entertainment
Employees are required to report gifts or entertainment that are given in the course of soliciting existing or potential clients and any investment related gifts or entertainment received as described above. This reporting obligation will not apply to gifts or entertainment of insubstantial value (such as promotional items or meals, provided it does not exceed $10 in value.) Gifts must be values at the higher of cost or market value exclusive of tax and delivery charges. Each employee will be required to certify every quarter that he or she has reported all gifts or entertainment given and/or received in accordance with this Code of Ethics. Employees who are registered representatives of Carillon Fund Distributors will be required to maintain and report gifts and/or entertainment provided in accordance with policies and procedures adopted by Carillon Fund Distributors.
Donations
Donations from SI at the request of existing or potential clients are permissible, but cannot exceed $2,000 per year per recipient. Any donation over $250 must be approved by the President of SI.
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V. OTHER PROVISIONS
Initial Public Offerings
All Supervised Persons shall not purchase any equity securities in an initial public offering.1
Market Timing
Supervised Persons are prohibited from engaging in any trading activities potentially injurious to any mutual funds sub-advised by SI as such activity is defined by the funds. This includes patterns of frequent trading or market timing when discouraged or prohibited by SI's fund clients.
Service as a Director
Supervised Persons are prohibited from serving on the boards of directors of publicly traded companies, absent prior authorization from the President of SI.
Disclosure of Holdings or Transaction Information
Supervised Persons are prohibited from disclosing holdings or transaction information of the Carillon Funds, fiduciary accounts or advisory clients other than to the client or others legally entitled to the information. Disclosures related to the holdings or transactions in the Carillon Funds are subject to the fund's policy on Disclosure of Portfolio Holdings expressed in the Carillon Funds' Compliance Manual. Any questions regarding the disclosure of holdings or transaction information should be posed to the Chief Compliance Officer.
Participation in Investment Clubs
Access Persons (as defined in the Personal Trading Annex below) are prohibited from participating in or contributing to Investment Clubs without notifying the Chief Compliance Officer. The Chief Compliance Officer may prohibit your participation in or contribution to an Investment Club. Transactions in Covered Securities are subject to the same preclearance, blackout, and reporting requirements as the Access Persons' other accounts.
Disciplinary Disclosures
All Supervised Persons are required to certify annually that they are not subject to any of the disciplinary events listed in Item 11 in the current Form ADV, Part 1 or disclose matters for which need to be reflected in the Form ADV.
VI. CERTIFICATION
Each newly hired Supervised Person will be provided a copy of the Code of Ethics and must certify in writing initially and annually thereafter that they have received a copy of the Code of Ethics, read and understand all provisions of the Code of Ethics, and agree to comply with the applicable terms of the Code of Ethics. Scout will provide its Supervised Persons with any
1"Initial Public Offering" means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934.
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amendments to the Code of Ethics and will require all Supervised Persons to certify in writing that they have received, read and understand the amendments.
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Code of Ethics-Personal Trading Annex
Scout Investments
Reams Asset Management Division
August 2019
This Scout Personal Trading Annex ("Policy") is meant to supplement the Scout Code of Ethics. Scout Investments ("SI"), including its Reams Asset Management Division ("Reams") has adopted this Policy with the objective of supplementing Scout's Code of Ethics and addressing potential conflicts of interest with regard to employee trading consistent with Scout's fiduciary standard of ethics as well as applicable law and regulation. Together, Scout's Code of Ethics and Personal Trading Annex are hereby referred to as the Code of Ethics and are intended to constitute Scout's written code of ethics as required by Rule 17j-1 under the Investment Company Act of 1940 and Scout's written code of ethics required Rule 204A-1 under the Investment Advisers Act of 1940.
Scope of Policy
This Policy applies to all Supervised Persons. A Supervised Person means any Scout employee who provides advice on behalf of Scout and who are subject to Scout's supervision and control.
Scout considers all Supervised Persons as Access Persons. An Access Person includes any:
(i)Supervised Person that has access to nonpublic information regarding any Clients' purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any Carillon Fund (or other Reportable Fund);
(ii)Supervised Person that is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic; or
(iii)officer, director or partner of Scout.
Non-employee directors of Scout are not subject to the restrictions and preclearance requirements of the Code, provided they have no knowledge of Scout's pending or current program trading activity in the securities they are trading. Such directors must provide an annual certification that with respect to all security transactions during the preceding year, the director was not aware of any Scout program activity relating to the security in question when the transaction was effected.
Limits on Trading
All Access Persons are subject to certain pre-clearance requirements and/or designated restrictions relating to transactions in Covered Securities (as defined under the Section "Definitions".) Except for those transactions listed below, all Access Persons must obtain pre- clearance for all purchase or sales in Covered Securities. Scout may authorize or deny any pre- clearance request based upon the obligations contained in this Policy and the overall Code of Ethics.
Pre-clearance requests must be submitted via an electronic system (Schwab Compliance Technologies) or, in limited circumstances (e.g. Limited Offerings or in the event of a system malfunction) through a form as directed by the Chief Compliance Officer. If the request is approved, the authorization is valid until the end of the next business day following the approval or in the case of a Limited Offering as directed by SI's Chief Compliance Officer. Any personal trade subject to these pre-clearance requirements that is placed as a "limit order" must also be
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placed as a "day order." The following purchases or sales in Covered Securities are exempt from the above pre-clearance requirements:
Purchases or sales by a Board Access Person that does not involve a Limited Offering;
Purchases or sales in an account which an Access Person has no direct or indirect influence or control;
Purchase or sales of securities which are non-voluntary on the part of the Access Person, including mergers, recapitalizations or similar transactions;
Purchases or sales pursuant to an Automatic Investment Plan ;
Purchases that are part of an issuer's automatic dividend reinvestment plan;
Purchases 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 the issuer, and sales of such rights are so acquired;
Purchases or sales in exchange traded funds and notes; or
Purchases or sales in open-end investment company shares.
Access Persons desiring to invest in a Limited Offering must receive prior authorization from SI's Chief Compliance Officer, or their designee. The Chief Compliance Officer, or their designee, will consider certain factors, including without limitation, applicable federal securities laws, the likelihood of a Client buying the Limited Offering, whether the Limited Offering is appropriate for a Client or any circumstances surrounding the Access Person's opportunity to acquire the Limited Offering.
Restricted Trades
Scout prohibits the following transactions of a Covered Security in which a Scout Access Person has Beneficial Ownership:
∙The purchase or sale of a Covered Security on the Restricted List, unless:
(i)the issuer of the Security has a market capitalization greater than $5 billion; and
(ii)the proposed transaction involves less than $100,000 of the issuer's
Securities. Trades on sequential business days are aggregated in calculating the $100,000 limit.
A Covered Security will be placed on the Restricted List if the Covered Security is held in an SI Client discretionary account, provided that the Restricted List will not include shares of an Investment Company.
∙The purchase or sale of a Covered Security if the Access Person is aware that a Client account has either executed a trade within seven (7) days or intends to execute a trade within seven (7) days, unless the Access Person:
(i)places the same transaction type as the Client's transaction, (e.g., buy or sell);
(ii)places the order after the execution of the Client's transaction; and
(iii)receives a price that is not better than the price received by the Client;
∙The purchase or sale of a Covered Security on the same day in which any Access Person knows that a Client Account has a pending "buy" or "sell" order in that same Covered
Security;
∙The sale of a Covered Security on the Restricted List within sixty (60) days of purchase at a price greater than any purchase within the sixty (60) day period, provided the Access Person may still sell the Security and disgorge any difference in the sale and purchase price;
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∙The writing of an option to purchase or sell a Covered Security on the Restricted List.
The Chief Compliance Officer may waive any of the above limitations for any Access Person provided the Access Person did not foresee the circumstances relating to the sale at the time of the purchase or the limitations on the transaction would otherwise cause great hardship to the Access Person. The Chief Compliance Officer must maintain a record of any exemptions made pursuant to this paragraph.
Prohibited Trades
All Supervised Persons are prohibited from trading based upon material non-public information, in accordance with Scout's Policy on Insider Trading. All Supervised Persons are subject to blackout restrictions pertaining to transactions in a Covered Security that he or she has Beneficial Ownership. A Blackout List will be maintained by a designated Compliance Officer and a Covered Security will be placed on the Blackout List if the Compliance Officer, in consultation with the Chief Compliance Officer and/or other appropriate personnel, determines that a Supervised Person has Material Non-Public Information (as defined in Scout's Policy on Insider Trading.) Access Persons are prohibited from purchasing or selling a Covered Security on the Blackout List.
Reporting Requirements for Access Persons
Access Persons
Except as described below, all Access Persons are required to:
∙File a Brokerage Accounts Report no later than 10 days after being designated as an Access Person.
∙File an Initial Holdings Report no later than 10 days after being designated as an Access Person.
∙File an Annual Holdings Report by January 30th each year for the previous twelve months beginning January 1st and ending December 31st.
∙File a Quarterly Transactions Report no later than 30 days after the end of each calendar quarter.
∙Notify each firm that maintains a brokerage account for them, or a Family Member, of their association with Scout and the requirement to receive duplicate copies of confirmations and periodic statements.
Brokerage Accounts Report
Every Access Person must submit a Brokerage Accounts Report no later than 10 days after the individual is designated as an Access Person. Each Access Person must disclose in this record each brokerage account in which they have any Beneficial Ownership (including the broker firm's name and the account number.) The statement also must include the brokerage account(s) for any Family Member of the Access Person. It is the responsibility of each Access Person to notify each firm through which they or a Family Member maintains an account of their affiliation with Scout. This record must be updated if new outside brokerage accounts are opened or closed at any time after the initial record is submitted and confirmed.
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Upon submission of this statement a designated Compliance Officer will send a request to receive duplicate confirmation and periodic statements. It is the Access Person's responsibility to ensure that the Compliance Department's request is honored.
Initial Holdings Report
Every Access Person must submit an Initial Holdings Report no later 10 days after the individual is designated as an Access Person. Information contained in the report must be current as of a date not more than 45 days prior to the date the individual becomes an Access Person. The Initial Holdings Report must contain the following information for each Covered Security in which the Access Person or Family Member has any direct or indirect Beneficial Ownership:
∙The title and type of each Covered Security, and as applicable the exchange ticker symbol or CUSIP number, number of shares and principal amount;
∙The name of any broker, dealer or bank with whom the Scout Access Person maintained an account in which any Securities were held for the direct or indirect benefit of the Scout Access Person;
∙The date the report is submitted by the Scout Access Person.
Quarterly Transaction Reports
Every Access Person must submit a Quarterly Transaction Report, no later than 30 days after the end of each calendar quarter with the following information for transactions in any Covered Security in which the Access Person or Family Member has any direct or indirect Beneficial Ownership:
∙The date of each transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, the number of shares, and the principal amount;
∙The nature of the transaction that is, a purchase, sale or other type of acquisition or disposition;
∙The price at which the transaction was effected;
∙The name of each broker, dealer, bank, or other financial institution maintaining a brokerage or other account for the Scout Access Person or Family Member and the account number assigned to it; and
∙The date the report is submitted.
The Access Person will not have to submit a Quarterly Transaction Report if duplicate trade confirmations or accounts statements are received by Scout within 30 days after the end of the applicable calendar quarter and contain the necessary information listed above. The Access Person will be responsible for confirming that the duplicate confirmations or account statements meets these requirements within 30 days after the end of the applicable calendar quarter.
Annual Holdings Report
Every Access Person must submit an Annual Holdings Report by January 30th of each year. Information contained in the report must be current as of a date not more than 45 days prior to the date the Access Person submits the report.
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The Initial Holdings Report and Annual Holdings Report must contain the following information for each Covered Security in which the Access Person or Family Member has any direct or indirect Beneficial Ownership:
∙The title and type of each Covered Security, and as applicable the exchange ticker symbol or CUSIP number, number of shares and principal amount;
∙The name of any broker, dealer or bank with whom the Scout Access Person maintained an account in which any Securities were held for the direct or indirect benefit of the Scout Access Person; and
∙The date the report is submitted by the Access Person.
Reporting Exemptions
Access Persons are not required to report:
∙Transactions in accounts or Securities held in accounts over which the Access Person has no direct influence or control (e.g., third-party fully discretionary managed account); and
∙Transactions effected pursuant to an Automatic Investment Plan.
Review of Access Person Reports
A designated Compliance Officer within the Compliance Group will assess Access Person trading activities and compare these activities to trading activity with certain accounts managed by SI, Reams, or other affiliates of Scout as appropriate. Any violations of the Code of Ethics shall be reported promptly to the Scout Chief Compliance Officer. Factors that will be considered in assessing personal trading activity include one or more of the following, but may not necessarily be limited to:
∙The nature of the Access Person's role relative to Client accounts;
∙The Access Person's access to nonpublic information regarding Client holdings;
∙The timing of the Access Person's receipt of information that contributes to that person being an Access Person (e.g., knowledge of trade activity before or shortly after trade placed by a Client account reflects different risk profile than receipt of a recommended list once a quarter);
∙Impact of SI, or affiliates of Scout trading volume in a particular security in comparison to market trading volume;
∙Proximity of the Access Person trade in relation to a Client trade and whether the trade took place before or after the trade within the Client account;
∙Potential that an Access Person's trading activity represents conduct prohibited by a
Reportable Fund;
∙Patterns of trading activity within the Access Person's account, and within a Client account if the Access Person has a vital role supporting the investment decisions in the
Client's account.
Certifications
Each Supervised Person will be provided a copy of the Code of Ethics and must certify in writing no later than 30 days after receipt that they have received the Code Ethics, read and understand the Code of Ethics and agree to comply with the applicable terms of the Code of Ethics. Scout will provide any amendments to the Code of Ethics and will require all Supervised Persons to
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certify in writing that they have received, read and understand the amendments. Each year the Chief Compliance Officer or compliance officer designated by the Chief Compliance Officer will conduct an annual meeting with all Supervised Persons to review the Code of Ethics and will require all Supervised Persons to annually certify that they have read, understood and complied with the Code of Ethics, that they have made all of the reports required by the Code of Ethics and have not engaged in any prohibited conduct.
Reporting Violations
All Supervised Persons are required to promptly report any actual, apparent or suspected violations of the Policy to the Chief Compliance Officer. If the Chief Compliance Officer or another compliance officer is not available the individual should report the violation to their immediate supervisor who is then responsible for reporting it to the Chief Compliance Officer. All reports will be treated confidentially to the extent permitted by law and investigated promptly.
Reporting to SI Board of Directors
At least annually, the Chief Compliance Officer of SI shall provide to the Scout Investments Board, a written report to: (i) describe any issues arising under the Code of Ethics or procedures since the last report to the board of trustees, including but not limited to, information about material violations of the Code of Ethics and sanctions imposed in response to the material violation; (ii) identify any recommended change to existing restrictions or procedures based upon the experience under the Code of Ethics, evolving industry practices and developments in applicable laws and regulations; and (iii) certify that SI has adopted policies and procedures reasonably necessary to prevent Access Persons from violating the Code of Ethics.
Amendments to the Code of Ethics
The board of directors of SI must approve any material amendment to the Code of Ethics no later than six months following the amendment.
Sanctions
Upon discovering a violation of this Policy, Scout and or Raymond James Financial may impose such sanctions as it deems appropriate, including, but not limited to, a letter of censure, discouragement of profits, suspension or termination of the violator's employment. For more information, please see the attached Exhibit A.
Records
Scout will be responsible for maintaining the following records:
1.A copy of the Code of Ethics;
2.A record of each Access Person;
3.A record of any violation of the Code of Ethics and of any actions taken as a result of the violation;
4.A copy of each written acknowledgement as described in the Section entitled
"Certifications";
5.A copy of each report made by an Access Person as required under the Code of Ethics, including any information provided in lieu of reports in the form of duplicate trade confirmations or account statements;
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6.A record of any decisions, and the reasons supporting the decision, to approve the acquisition of securities in a Limited Offering by an Access Person; and
A complete description of Scout's recordkeeping responsibility under this Code of Ethics is contained in the Books and Records Policy.
Definitions
"Automatic Investment Plan" means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.
"Beneficial Ownership" shall be interpreted in accordance with Rule 16a-1(a)(2) under the Securities Exchange Act of 1934.
"Client" means an investment client of SI.
"Control" or "Controlled" shall be interpreted in accordance with Section 2(a)(9) of the Investment Company Act of 1940.
"Covered Security" means a security as defined in Section 202(a)(18) of the Investment Advisers Act of 1940 and Section 2(a)(36) of the Investment Company Act, except that it does not include:
(i)direct obligations of the Government of the United States; (ii) bankers' acceptances, bank
certificate of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements; and (iii) shares issued by money-market funds; (iv) shares issued by open-end registered investment companies other than a Reportable Fund; (v) shares issued by unit investment trusts that are invested exclusively in one or more open-end investment companies other than a Reportable Fund.
"Family Member" means any individual who is a member of a Supervised Person's immediate family who lives in the Supervised Person's household.
"Fixed Income Client" means any Client of SI that is managed by a portfolio manager within the Reams Asset Management division.
"Initial Public Offering" means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the Securities Exchange Act of 1934.
"Investment Company" means a company registered as such under the Investment Company Act of 1940, including but not limited to, open-end mutual funds, close-end mutual funds, and unit investment trusts, but does not include a money market mutual fund.
"Limited Offering" means an offering exempt from registration under the Securities Act of 1933 pursuant to Section 4(2) or Section 4(6) thereof, or pursuant to Rule 504, Rule 505 or Rule 506 adopted thereunder.
"Purchase or sale of a Covered Security" means the purchase or sale of a Covered Security, including the writing of an option to purchase or sell a Covered Security, in which the Access Person or their Family Member has Beneficial Ownership.
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"Reportable Fund" means any Investment Company for which SI acts as sub-adviser or investment adviser as defined in Section 2(a)(20) of the Investment Company Act of 1940 or any Investment Company whose investment adviser or principal underwriter Controls Scout, is Controlled by Scout or is under common Control with Scout.
"Security" or "Securities" means a security as defined in Section 202(a)(18) of the Investment Advisers Act of 1940 and Section 2(a)(36) of the Investment Company Act of 1940.
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APPENDIX A SCHEDULE OF SANCTIONS
This Schedule is intended to provide guidance in response to specific violations of the Code of Ethics, including the Personal Trading Policy. Any other violations of the Code of Ethics or Personal Trading Policy (e.g., improper frequent trading, use of material non-public information) will be handled on a case-by-case basis and can result in any of the penalties listed below. Depending on the nature of a violation, the penalty (e.g., suspension of trading privileges) may be imposed regardless of the timing or number of occurrences. Nothing in this Appendix should be viewed as limiting the ability of Scout or Raymond James to impose additional employment sanctions up to and including suspension or termination of employment for failing to abide by the Code of Ethics or Personal Trading Policy.
Pre-Clear |
|
Violation* |
|
1st |
Informal Warning |
2nd |
Written Warning |
3rd |
Suspension of Trading Privileges |
*If an employee fails to obtain prior authorization and the trade would have been prohibited under the Policy, in addition to the penalties list above, the employee will be required to disgorge any profits resulting from the personal trade.
Late |
|
Reporting |
|
|
|
1st |
Informal Warning |
2nd |
Written Warning |
3rd |
Suspension of Trading Privileges |
|
|
Inaccurate or |
|
Failure to Report |
|
1st |
Informal Warning |
2nd |
Written Warning |
3rd |
Suspension of Trading Privileges |
For this schedule, accumulation of violations will be based on a rolling 12 month period. However, an accumulation of 3 or more warnings during the course of an employees' employment with Scout can result in the suspension of that employees' trading privileges (up to 30 days).
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CODE OF ETHICS AND CONDUCT
T. ROWE PRICE GROUP, INC.
AND ITS AFFILIATES
Effective December 1, 2019
CODE OF ETHICS AND CONDUCT
OF
T. ROWE PRICE GROUP, INC.
AND ITS AFFILIATES
TABLE OF CONTENTS |
|
Sarbanes-Oxley Codes ............................................................................................................. |
|
Questions Regarding the Code ................................................................................................. |
1-4 |
STANDARDS OF CONDUCT OF PRICE GROUP AND ITS PERSONNEL ......................... |
|
Anti-Bribery Laws and Prohibitions Against Illegal Payments ............................................... |
|
2-2,7-1 |
|
Anti-Money Laundering........................................................................................................... |
|
i-1 |
|
Employment of Former Government and Self-Regulatory Organization Employees ......... |
|
2-9,4-1 |
|
Past and Current Litigation and Inquiries from Regulators or Governmental Organizations 2-10
2-16,6-1 |
|
STATEMENT OF POLICY ON GIFTS AND BUSINESS ENTERTAINMENT ..................... |
|
STATEMENT OF POLICY ON MATERIAL, INSIDE (NON-PUBLIC) INFORMATION.... 4-1 |
|
STATEMENT OF POLICY ON SECURITIES TRANSACTIONS .......................................... |
|
STATEMENT OF POLICY ON SYSTEMS SECURITY AND RELATED ISSUES............. |
|
STATEMENT OF POLICY ON COMPLIANCE WITH ANTITRUST LAWS ....................... |
|
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CODE OF ETHICS AND CONDUCT
OF
T. ROWE PRICE GROUP, INC.
AND ITS AFFILIATES
GENERAL POLICY STATEMENT
Purpose of Code of Ethics and Conduct. As a global investment management firm, we are considered a fiduciary to many of our clients and owe them a duty of undivided loyalty. Our clients entrust us with their financial well-being and expect us to always act in their best interests. Over the course of our Company's history, we have earned a reputation for fair dealing, honesty, candor, objectivity and unbending integrity. This has been possible by conducting our business on a set of shared values and principles of trust.
In order to educate our personnel, protect our reputation, and ensure that our tradition of integrity remains as a principle by which we conduct business, T. Rowe Price Group, Inc. ("T. Rowe Price," "TRP", "Price Group" or "Group") has adopted this Code of Ethics and Conduct ("Code"). Our Code establishes standards of conduct that we expect each associate to fully understand and agree to adopt. As we are in a highly regulated industry, we are governed by an ever-increasing body of federal, state, and international laws as well as countless rules and regulations which, if not observed, can subject the firm and its employees to regulatory sanctions. All associates are expected to comply with all laws and regulations applicable to T. Rowe Price business. Our Code contains 31 separate Standards of Conduct as well as the following six separate Statements of Policy:
1.Statement of Policy on Gifts and Business Entertainment
2.Statement of Policy on Material, Inside (Non-Public) Information
3.Statement of Policy on Securities Transactions
4.Statement of Policy on Systems Security and Related Issues
5.Statement of Policy on Compliance with Antitrust Laws
6.Statement of Policy on Privacy
A copy of this Code will be retained by the Legal Department for five years from the date it is last in effect. While the Code is intended to provide you with guidance and certainty as to whether or not certain actions or practices are permissible, it does not cover every issue that you may face. The firm maintains other compliance-oriented manuals and handbooks that may be directly applicable to your specific responsibilities and duties. Nevertheless, the Code should be viewed as a guide for you and the firm as to how we jointly must conduct our business to live up to our guiding tenet that the interests of our clients and customers must always come first.
Each new employee will be provided with the current Code and must acknowledge their understanding of the Code. All employees have access to the current Code on the intranet. Each employee will be required to provide Price Group with an acknowledgement of their understanding of the current Code on at least an annual basis. All acknowledgements will be retained as required by the Investment Advisers Act of 1940 (the "Advisers Act").
Please read the Code carefully and observe and adhere to its guidance. 1-1
Persons and Entities Subject to the Code. Unless otherwise determined by the Chairperson of the Ethics Committee, the following entities and individuals are subject to the Code:
∙Price Group
∙The subsidiaries and affiliates of Price Group
∙The officers, directors and employees of Price Group and its affiliates and subsidiaries
Unless the context otherwise requires, the terms "T. Rowe Price", "Price Group" and "Group" refer to Price Group and all its affiliates and subsidiaries.
In addition, the following persons are subject to the Code:
1.Any contingent worker (independent or agency-provided contract worker) whose assignments exceed four weeks or whose cumulative assignments exceed eight weeks over a twelve-month period and whose work is closely related to the ongoing work of Price Group employees (versus project work that stands apart from ongoing work); and
2.Any contingent worker whose assignment is more than casual in nature or who will be exposed to the kinds of information (via systems access or otherwise) and situations that would create conflicts on matters covered in the Code.
The independent directors of Price Group and the Price Funds are subject to the principles of the Code generally and to specific provisions of the Code as noted.
Definition of Supervised Persons. Under the Advisers Act, the officers, directors (or other persons occupying a similar status or performing similar functions) and employees of the Price Advisers, as well as any other persons who provide advice on behalf of a Price Adviser and are subject to the Price Adviser's supervision and control are "Supervised Persons".
Status as a Fiduciary. Several of Price Group's subsidiaries are investment advisers registered with the U.S. Securities and Exchange Commission ("SEC"). These include T. Rowe Price Associates, Inc. ("TRPA"), T. Rowe Price International Ltd ("TRPIL"), T. Rowe Price Advisory Services, Inc. ("TRPAS"), T. Rowe Price (Canada), Inc. ("TRP Canada"), T. Rowe Price Singapore Private Ltd. ("TRPSING"), T. Rowe Price Japan, Inc. ("TRPJ"), T. Rowe Price Australia Limited ("TRPAU"), and T. Rowe Price Hong Kong Limited ("TRPHK").
TRPIL is also authorized and regulated by the UK Financial Conduct Authority ("FCA"). TRPIL is also subject to regulation by the Dubai Financial Services Authority (in respect of its DFIC Representative Office).
TRPHK is also authorized and regulated by the Securities and Futures Commission ("SFC") of Hong Kong.
TRPSING is also authorized and regulated by the Monetary Authority of Singapore ("MAS").
TRP Canada is also registered with the Ontario Securities Commission, the Manitoba Securities Commission, the British Columbia Securities Commission, the Saskatchewan Financial Services
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Commission, the Nova Scotia Securities Commission, the New Brunswick Securities Commission, the Financial Markets Authority (Quebec), and the Alberta Securities Commission.
TRPJ is licensed by the Japan Financial Services Authority ("FSA").
TRPAU also holds an Australian Financial Services License issued by the Australian Securities & Investments Commission ("ASIC").
All advisers affiliated with Price Group will be referred to collectively as the "Price Advisers" unless the context otherwise requires. The Price Advisers will register with additional securities regulators as required by their respective businesses. The primary responsibility of the Price Advisers is to render to their advisory clients on a professional basis unbiased advice regarding their clients' investments. As investment advisers, the Price Advisers have a fiduciary relationship with all of their clients, which means that they have an absolute duty of undivided loyalty, fairness and good faith toward their clients and mutual fund shareholders and a corresponding obligation to refrain from taking any action or seeking any benefit for themselves which would, or which would appear to, prejudice the rights of any client or shareholder or conflict with his or her best interests.
Adviser Act Requirements for Supervised Persons. The Advisers Act requires investment advisers to adopt Codes that:
∙Establish a standard of business conduct, applicable to Supervised Persons, reflecting the fiduciary obligations of the adviser and its Supervised Persons;
∙Require Supervised Persons to comply with all applicable laws;
∙Require Supervised Persons to report violations of the Code promptly to the adviser's Chief Compliance Officer; and
∙Require the adviser to provide each Supervised Person with a copy of the Code and any amendments and requiring Supervised Persons to provide the adviser with an acknowledgement of receipt of the Code and any amendments.
Price Group applies these requirements to all persons subject to the Code, including all Supervised Persons.
NASDAQ Requirements. Nasdaq Stock Market, Inc. ("NASDAQ") rules require listed companies to adopt a Code of Conduct for all directors, officers, and employees. Price Group is listed on NASDAQ. This Code is designed to fulfill this NASDAQ requirement. A waiver of this Code for an executive officer or director of T. Rowe Price Group, Inc. must be granted by Price Group's Board of Directors and reported as required by the pertinent NASDAQ rule.
What the Code Does Not Cover. The Code was not written for the purpose of covering all policies, rules and regulations to which personnel may be subject. For example, T. Rowe Price Investment Services, Inc. ("Investment Services") is regulated by the Financial Industry Regulatory Authority ("FINRA") and, as such, is required to maintain written supervisory procedures to enable it to supervise the activities of its registered representatives and associated persons to ensure compliance with applicable securities laws and regulations and with the applicable rules of FINRA. In addition, TRPIL, TRP Canada, and other TRP entities are subject to several non-U.S. regulatory authorities.
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Sarbanes-Oxley Codes. The principal Executive and Senior Financial Officers of Price Group and the Price Funds are also subject to codes (collectively the "S-O Codes") adopted to bring these entities into compliance with the applicable requirements of the Sarbanes-Oxley Act of 2002 ("Sarbanes-Oxley Act"). These S-O Codes, which are available along with this Code on the firm's intranet site, are supplementary to this Code, but administered separately from it and each other.
Compliance Procedures for Funds and Federal Advisers. Under rule 38a-1 of the Investment Company Act of 1940, each fund board is required to adopt written policies and procedures reasonably designed to prevent the fund from violating federal securities laws. These procedures must provide for the oversight of compliance by the fund's advisers, principal underwriters, administrators and transfer agents. Under Rule 206(4)-7 of the Investment Advisers Act of 1940, it is unlawful for an investment adviser to provide investment advice unless it has adopted and implemented policies and procedures reasonably designed to prevent violations of federal securities laws by the adviser and its supervised persons.
Compliance with the Code. Strict compliance with the provisions of this Code is considered a basic condition of employment or association with the firm. An employee may be subject to disciplinary action, up to and including termination, for refusing to cooperate with an internal or external investigation. An employee may be required to surrender any profit realized from a transaction that is deemed to be in violation of the Code. In addition, a breach of the Code may constitute grounds for disciplinary action, including fines and dismissal from employment. Employees may appeal to the Management Committee any ruling or decision rendered with respect to the Code.
Questions regarding the Code should be referred to Code_of_Ethics@TRowePrice.com
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STANDARDS OF CONDUCT OF PRICE GROUP AND ITS PERSONNEL
Allocation of Brokerage Policy. The policies of each of the Price Advisers with respect to the allocation of client brokerage are set forth in Part 2A of Form ADV of each of the Price Advisers. The Form ADV is each Price Adviser's registration statement filed with the SEC. It is imperative that all employees, especially those who are in a position to make recommendations regarding brokerage allocation or who are authorized to select brokers that will execute securities transactions on behalf of our clients, read and become fully knowledgeable concerning our policies in this regard. Any questions regarding any of the Price Advisers' allocation policies for client brokerage should be addressed to the respective Equity Best Execution or Fixed Income Best Execution Committee.
Annual Compliance Certification. Annually each person subject to the Code is required to complete an Annual Compliance Certification ("ACC") regarding his or her compliance with various provisions of the Code. Associates must notify Code Compliance (via the Code of Ethics mailbox) should any responses to these questions change during the subsequent calendar year. Each Access Person (defined on page 5-3), except the independent directors of the Price Funds, must file an Initial Holdings Report as well as complete the ACC which will include a reporting and certification of securities accounts and holdings.
Anti-Bribery Laws and Prohibitions Against Illegal Payments. State, U.S., and international laws prohibit the payment of bribes, kickbacks, inducements or other illegal gratuities or payments by or on behalf of Price Group. Price Group, through its policies and practices, is committed to comply fully with these laws. T. Rowe Price prohibits its employees as well as anyone acting on its behalf from making any type of illegal payment. The U.S. Foreign Corrupt Practices Act ("FCPA") makes it a crime to directly or indirectly pay, promise to pay, offer to pay or authorize the payment of any money or anything of value to any government official in connection with obtaining or retaining business or influencing such official in order to secure an improper advantage. The term "government official" is broadly defined to include any officer or employee of a government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality thereof, or for or on behalf of any such public international organization, and any political party, party official or candidate for public office.
Additionally, the UK Bribery Act 2010 ("Bribery Act") contains wide prohibitions on illegal payments and specifically prohibits bribery between private parties. Also, the Bribery Act provides for severe civil and criminal penalties against individuals and corporations.
Under these Anti-bribery laws, actions constituting a bribe or illegal payment are interpreted broadly and could include excessive, repeated or lavish entertainment and/or gifts. Associates must adhere to the guidelines of gift and business entertainment policy and procedures and, if required by the applicable procedure, indicate in the reporting process whether a recipient of a gift or business entertainment is a government official.
If you are solicited to make or receive an illegal payment or have any questions about this section of the Code, you should contact the Legal Department. Also, an anonymous Hotline (888-651- 6223) has been established for employees to report any concerns they have regarding illegal payments, including potential violations of the FCPA and the Bribery Act.
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Antitrust. The U.S. antitrust laws are designed to ensure fair competition and preserve the free enterprise system. Other jurisdictions have requirements based on similar principals. Some of the most common antitrust issues with which an employee may be confronted are in the areas of pricing (adviser fees) and trade association activity. To ensure its employees' understanding of these laws, Price Group has adopted a Statement of Policy on Compliance with Antitrust Laws (page 7-1).
Anti-Money Laundering. T. Rowe Price has a legal and fiduciary duty to help guard against accounts under management from being used for fraudulent activities, money laundering, or the financing of terrorist activities. T. Rowe Price will not knowingly engage in any activity that facilitates money laundering or the funding of terrorist or criminal activities. The firm has developed procedures to help detect and prevent such activity from occurring and will comply with all laws and regulations to which T. Rowe Price is subject including those rules and regulations requiring the reporting of suspicious activity. It is each associate's responsibility to protect the firm from exploitation by money launderers. Refer to the Global Financial Crimes Prevention web-based training in myLearning for more information on money laundering and the relevant laws and regulations.
Appropriate Conduct. Associates are expected to conduct themselves in an appropriate and responsible manner in the workplace, when on company business outside the office, and at company-sponsored events. Inappropriate behavior reflects poorly on the associate and may impact T. Rowe Price. Managers should be especially mindful that they should set the standard for appropriate behavior.
Charitable Contributions. Employees should be sensitive to a possible perception of undue influence before making or requesting charitable contributions to or from a client, prospect, vendor, or other business contact. Under certain Anti-bribery laws, regulators may consider charitable contributions to be improper payments, even when the person who has requested that the contribution be made receives no direct monetary benefit. Accordingly, when making charitable contributions in response to requests from business contacts, associates must be mindful of how Anti-bribery laws could be implicated. In no case should charitable contributions be made on a quid pro quo basis.
Supervision of Charitable Contribution Requests. Managers and Division Heads are responsible for ensuring that responses to requests from clients, vendors, and other business contact and our requests to clients, vendors, and other business contacts for charitable contributions comply with these guidelines as well as respective departmental policies. Charitable contributions should be considered as separate and distinct from marketing and advertising expenditures. If you have any questions about a proposed charitable contribution, you should contact the Chairperson of the Ethics Committee before proceeding.
Requests Received from Clients, Vendors or Other Business Contacts for Corporate Charitable Contributions. On occasion, a T. Rowe Price entity may be asked by an employee of a client, vendor, or other business contact to make a charitable donation. In those instances where the T. Rowe Price Foundation does not make the contribution, the decision about the charitable contribution is made by the T. Rowe Price entity, subject to the following conditions:
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∙The amount of charitable contribution may not be linked to the actual or anticipated level of business with the client, vendor or other business contact whose employee is soliciting the charitable contribution;
∙There is no reason to believe that the employee requesting the contribution will derive an improper economic or pecuniary benefit as a result of the proposed contribution;
∙If the T. Rowe Price entity considering the contribution is unfamiliar with the charity, its personnel should confirm with the Central Control Group that the charity does not appear on the Office of Foreign Assets Control's Specially
Designated Nationals List;
∙The contribution should be made payable directly to the charity; and
∙Associates of the T. Rowe Price entity considering the contribution should check with Finance to determine the appropriate T. Rowe Price entity to make the contribution.
In addition, if the requested amount exceeds $1,000 the request must be referred to the Chairperson of the Ethics Committee for prior approval.
Some broker-dealer's sponsor days, often referred to as "miracle" days, where they pledge that proceeds received on that day will be donated to a specific charity. Because of fiduciary and best execution obligations, the Price Advisers cannot agree to direct trades to a broker-dealer in support of such an event at either a client's or the broker-dealer's request. The Price Advisers are not prohibited, however, from placing trades for best execution that happen to occur on a "miracle" day or similar time and thus benefit a charity.
Requests Received from Clients, Vendors or Other Business Contacts for Personal Charitable Contributions. On occasion, a T. Rowe Price employee may be asked by an employee of a client, vendor or other business contact to make a charitable contribution. If the employee makes a contribution directly to the charity and the contribution is not made in the name of or for the benefit of the business contact, no Code of Ethics or FINRA issues arise. For example, a plan fiduciary might mention that her husband has recently recovered from a heart problem and that she is raising funds for a charity that supports cardiac research. The T. Rowe Price employee can make a personal contribution to that charity and if the contribution is not tied to the name of the business contact and does not create a benefit for her, the employee does not need to request prior clearance of or notify T. Rowe Price about the contribution.
However, personal charitable contributions made in the name of and for the benefit of a business contact should be treated as "gifts" to the business contact. For example, if the business contact raises a certain amount of money, he or she gets a tangible award or opportunity like the chance to participate in a marathon. For business contacts related to T. Rowe Price fund business or other broker-dealer related business, contributions of the latter type are subject to FINRA's $100 limit. For other business activities not regulated by FINRA, contributions in excess of $100 must be prior approved by the Chairperson of the Ethics Committee.
Requests to Clients, Vendors, or Other Business Contacts for Charitable Contributions. Employees should be sensitive to a possible perception of undue influence
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before requesting a client, vendor, business contact or an employee of such an entity to make a charitable contribution. In no case should such a request be made on a quid pro quo basis. If you have any questions about requesting a charitable contribution you should contact the Chairperson of the Ethics Committee before proceeding.
NASDAQ Listing Rules. Under the NASDAQ listing rules, specific restrictions may apply to contributions to a charitable organization for which an independent director of T. Rowe Price Group, Inc. serves as an officer. Specifically, contributions to such organizations during a fiscal year may not exceed the higher of five percent of the organizations revenues or $200,000. Contributions in excess of these thresholds may invalidate a director's "independent" classification.
Conflicts of Interest. All employees must avoid placing themselves in a "compromising position" where their interests may be in conflict with those of Price Group or its clients. In addition, employees are legally required to perform their job duties in the best interests of the firm; referred to as a duty of loyalty. This means that employees cannot enrich themselves at the expense of T. Rowe Price, actively compete with the firm, divert business to a competitor, and must always seek to protect the assets of the T. Rowe Price.
Relationships with Profitmaking Enterprises. Depending upon the circumstances, an employee may be prohibited from creating or maintaining a relationship with a profitmaking enterprise. In all cases, written approval must be obtained as described below.
General Prohibitions. Employees are generally prohibited from serving as officers or directors of any issuer (company) that is approved or likely to be approved for purchase in our firm's client accounts. In addition, an employee may not accept or continue outside employment that will require him or her to become registered (or duly registered) as a representative of an unaffiliated broker-dealer, investment adviser or insurance broker or company unless approval to do so is first obtained in writing from the Chief Compliance Officer ("CCO") of the broker- dealer. An employee also may not become independently registered as an investment adviser.
Approval Process. Any outside business activity, which may include a second job, appointment as an officer or director of or a member of an advisory board to a for-profit enterprise, or self-employment, must be approved in writing by the employee's supervisor. If the employee is a registered representative of T. Rowe Price Investment Services, he or she must provide the Legal Registration Group with prior written notice. Any reported outside business activity of a registered representative is reviewed by Investment Services' CCO, or designee, in order to determine if disclosure to FINRA is required.
Review by Ethics Committee. If an employee contemplates obtaining an interest or relationship that might conflict or appear to conflict with the interest of Price Group, he or she must also receive the prior written approval of the Chairperson of the Ethics Committee or his or her designee and, as appropriate, the Ethics Committee itself. Examples of relationships that might create a conflict or appear to create a conflict of interest may include appointment as a director, officer or partner of or member of an advisory board to an outside profitmaking enterprise,
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employment by another firm in the securities industry, or self-employment in an investment capacity. Decisions by the Ethics Committee regarding such positions in outside profitmaking enterprises may be reviewed by the Management Committee before becoming final.
Approved Service as Director or Similar Position. Certain employees may serve as directors or as members of creditor committees or in similar positions for non- public, for-profit entities in connection with their professional activities at the firm. An employee must receive the written permission of the Management Committee before accepting such a position and must relinquish the position if the entity becomes publicly held, unless otherwise determined by the Management Committee.
Service with Nonprofitmaking Organizations. Price Group encourages its employees to become involved in community programs and civic affairs. However, employees should not permit such activities to affect the performance of their job responsibilities.
Approval Process. The approval process for service with a non-profitmaking organization varies depending upon the activity undertaken.
By Supervisor. An employee must receive the approval of his or her supervisor in writing before accepting a position as an officer, trustee, or member of the Board of Directors of any nonprofit organization.
By Ethics Committee Chairperson. If there is any possibility that the organization will issue and/or sell securities, the employee must also receive the written approval of the Chairperson of the Ethics Committee or his or her designee and, as appropriate, the Chief Compliance Officer of the broker-dealer before accepting the position.
Although individuals serving as officers, Board members or trustees for nonprofitmaking entities that will not issue or sell securities do not need to receive this additional approval, they must be sensitive to potential conflict of interest situations (e.g., the entity is considering entering a business relationship with a T. Rowe Price entity) and must contact the Chairperson of the Ethics Committee for guidance if such a situation arises.
Relationships with Financial Services Firms. In order to avoid any actual or apparent conflicts of interest, employees are prohibited from investing in or entering into any relationship, either directly or indirectly, with corporations, partnerships, or other entities that are engaged in business as a broker, a dealer, an underwriter, and/or an investment adviser. As described above, this prohibition generally extends to registration and/or licensure with an unaffiliated firm. This prohibition, however, is not meant to prevent employees from purchasing publicly traded securities of broker-dealers, investment advisers or other companies engaged in the mutual fund industry. All such purchases are subject to prior transaction clearance and reporting procedures, as applicable. This policy also does not preclude an employee from engaging an outside investment adviser to manage his or her assets.
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If any member of employee's immediate family is employed by or has a partnership interest in a broker-dealer, investment adviser, or other entity engaged in the mutual fund industry, the relationship must be reported to the Ethics Committee.
An ownership interest of 0.5% or more in any entity, including a broker-dealer, investment adviser or other company engaged in the mutual fund industry, must be reported to the Code Compliance Team.
Relationships with a Bank. In order to avoid any regulatory conflicts of interests associated with an outside business activity associated with a bank, employees are required to obtain prior written approval before engaging in any outside business activity with a bank.
Approval Process. Any outside business activity with a bank, such as a second job, must be approved in writing by the employee's supervisor and by the Chairperson of the Ethics Committee, or his designee.
Existing Relationships with Potential Vendors. If an employee is going to be involved in the selection of a vendor to supply goods or services to the firm, he or she must disclose the existence of any ongoing personal or family relationship with any principal of the vendor to the Chairperson of the Ethics Committee in writing before becoming involved in the selection process.
Investment in Client/Vendor Company Stock. In some instances, existing or prospective clients (e.g., clients with full-service relationships with T. Rowe Price Retirement Plan Services, Inc.) or vendors ask to speak to our portfolio managers and/or analysts who have responsibility for a Price Fund or other managed account in an effort to promote investment in their securities. While these meetings present an opportunity to learn more about the client/vendor and may therefore be helpful to T. Rowe Price, employees must be aware of the potential conflicts presented by such meetings. In order to avoid any actual or apparent conflicts of interest:
∙Employees are prohibited from providing any internal information (e.g., internal ratings or plans for future Price Fund or other client account purchases) to the client or vendor regarding the securities, except to the extent specifically authorized by the Legal Department, and
∙Investment decisions of employees regarding a client's or vendor's securities must be made independently of the client or vendor relationship and cannot be based on any express or implied quid pro quo. If a situation arises where a client has suggested that it is considering either expanding or eliminating its relationship with T. Rowe Price (or, in the case of a vendor, offering a more or less favorable pricing structure) based upon whether Price increases purchases of the client's or vendor's securities, the Chairperson of the Ethics Committee should be consulted immediately for guidance.
In addition, the use of information derived from such meetings with existing or prospective clients or vendors must conform to the Statement of Policy on Material, Inside (Non- Public) Information.
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Conflicts in Connection with Proxy Voting. If a portfolio manager or analyst with the authority to vote a proxy or recommend a proxy vote for a security owned by a Price Fund or a client of a Price Adviser has an immediate family member who is an officer or director or has a material business relationship with the issuer of the security, the portfolio manager or analyst should inform the Proxy Committee of the relationship so that the Proxy Committee can assess any conflict of interest that may affect whether the proxy should or should not be voted in accordance with the firm's proxy voting policies.
Confidentiality. The exercise of confidentiality extends to the all areas of our operations, including internal operating procedures and planning; current, prospective and former clients; investment advice; investment research; employee information and contractual obligations to protect third party confidential information. The duty to exercise confidentiality applies not only while associates and others are with the firm, but also after a person leaves the firm. Following are examples of the type of confidential information with which associates may come into contact:
∙Internal operating procedures and planning, including methods of operation and portfolio management, corporate financial information, and future initiatives the firm is considering.
∙Client information, including the identity of current, prospective, or former clients of any type (e.g., mutual fund shareholder, separate account client, etc.), agents of clients, and related data concerning clients (e.g., government-issued numbers, account numbers, addresses, investments, etc.).
∙Confidential information of third parties with whom we deal, such as the business operations of a vendor we use.
∙Investment research, including what securities we are considering for purchase or sale on behalf of our commingled investment vehicles or clients.
∙Information about our associates and contractors, such as name, government-issued numbers, health conditions, and financial or performance information.
∙Portfolio holdings for a commingled investment vehicle or separate account.
In addition to laws that can apply to the collection and use of such information, Price Group also may be subject to contractual commitments. It is important to remember that your role is to use confidential information of others, such as information of clients or other associates, only as needed to perform your job; to handle such information in a secure manner; to not use or share such data for your own or other non-business purposes; and to promptly report any potential issues about the security, availability, or integrity of such information to the Help Desk.
Expense Payments and Reimbursements. As a general rule, T. Rowe Price will not pay or reimburse expenses, such as travel, accommodation and meals, to a business contact and will not accept payment or reimbursement from a business contact for those types of expenses. Exceptions may only be granted with approval of the employee's supervisor and Division Head and the Chairperson of the Ethics Committee. Business units may adopt policies and procedures that permit T. Rowe Price to pay or reimburse expenses incurred by business contacts for attendance at certain T. Rowe Price sponsored events. Such policies and procedures must contain provisions that describe the circumstances in which such payments are allowed and the controls and conditions that will apply. Additionally, the policies and procedures must be approved by the Division Head and the Chairperson of the Ethics Committee. This general rule does not apply to
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"business entertainment" which is covered in the Statement of Policy on Gifts and Business Entertainment.
Financial Reporting. Price Group's records are maintained in a manner that provides for an accurate record of all financial transactions in conformity with generally accepted accounting principles. No false or deceptive entries may be made, and all entries must contain an appropriate description of the underlying transaction. All reports, vouchers, bills, invoices, payroll and service records and other essential data must be accurate, honest and timely and should provide an accurate and complete representation of the facts. The Audit Committee of Price Group has adopted specific procedures regarding the receipt, retention and treatment of certain auditing and accounting complaints. Refer to Responsibility to Report Violations on page 2-14.
Gifts and Business Entertainment. The firm has adopted a comprehensive policy on providing and receiving gifts and business entertainment, which is found in the Code in the Statement of Policy on Gifts and Business Entertainment (page 3-1).
Human Resources. Associates should refer to the appropriate Associate Handbook for more information on the policies referenced in this section as well as other Human Resources policies.
Equal Opportunity. Price Group is committed to the principles of equal employment opportunity ("EEO") and the maximum optimization of our associates' abilities. We believe our continued success depends on the equal treatment of all employees and applicants without regard to race, religion, creed, color, national origin, sex, gender, age, physical and mental disability, marital status, sexual orientation, gender identity or expression, citizenship status, military and veteran status, pregnancy, or any other classification protected by federal, state or local laws.
This commitment to EEO covers all aspects of the employment relationship including recruitment, application and initial employment, promotion, transfer, training and development, compensation, and benefits. All associates of T. Rowe Price are expected to comply with the spirit and intent of our EEO Policy. If you feel you have not been treated in accordance with this policy, contact your immediate supervisor, the appropriate Price Group manager or a Human Resources representative. No retaliation will be taken against you if you report an incident of alleged discrimination in good faith.
Drug and Alcohol Policy. Price Group is committed to providing a drug-free workplace and preventing alcohol abuse in the workplace. Drug and alcohol misuse and abuse affect the health, safety, and well-being of all Price Group associates and customers and restrict the firm's ability to carry out its mission. Associates must perform job duties unimpaired by illegal drugs or the improper use of legal drugs or alcohol.
Policy Against Harassment and Discrimination. Price Group is committed to providing a safe working environment in which all individuals are treated with respect and dignity. Associates have the right to enjoy a workplace that is conducive to high performance, promotes equal opportunity, and prohibits discrimination including harassment.
Price Group will not tolerate harassment, discrimination, or other types of inappropriate behavior directed by or toward an associate, supervisor/manager, contractor, vendor, customer, visitor, or other business partner. Accordingly, the firm will not tolerate
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harassment or intimidation of any associate based on race, religion, creed, color, national origin, sex, gender, age, disability, marital status, sexual orientation, gender identity or expression, citizenship status, veteran status, pregnancy discrimination, or any other classification protected by country, federal, state, or local law. In addition, Price Group does not tolerate slurs, threats, intimidation, or any similar written, verbal, physical, or computer-related conduct that denigrates or shows hostility or aversion toward any individual. Harassment will not be tolerated on our property or in any other work-related setting such as business-sponsored social events or business trips. If you are found to have engaged in conduct inconsistent with this policy, you will be subject to appropriate disciplinary action, up to and including, termination of employment.
Health and Safety in the Workplace. Price Group recognizes its responsibility to provide personnel a safe and healthful workplace and proper facilities to help them perform their jobs effectively.
Use of Employee Likenesses and Information. Price Group is permitted to use employees' names, biographical information, images, job descriptions, and other relevant business data for purposes of complying with legal requirements and/or as part of its legitimate interests in managing its business, including any T. Rowe Price sponsored community or charitable event. Price Group will seek an employee's explicit consent for a proposed use of the employee's likeness or other information when required to do so under applicable law.
Employment of Former Government and Self-Regulatory Organization Employees. U.S. laws and regulations govern the employment of former employees of the U.S. Government and its agencies, including the SEC. In addition, certain states have adopted similar statutory restrictions. Finally, certain states and municipalities that are clients of the Price Advisers have imposed contractual restrictions in this regard. Before any action is taken to discuss employment by Price Group of a former government or regulatory or self-regulatory organization employee, whether in the U.S. or internationally, guidance must be obtained from the Legal Department.
Inside Information. The purchase or sale of securities while in possession of material, inside information is prohibited by U.S., UK, and other international, state and other governmental laws and regulations. Information is considered inside and material if it has not been publicly disclosed and is sufficiently important that it would affect the decision of a reasonable person to buy, sell or hold securities in an issuer, including Price Group. Under no circumstances may you transmit such information to any other person, except to Price Group personnel who are required to be kept informed on the subject. You should read and understand the Statement of Policy on Material, Inside (Non-Public) Information.
Investment Clubs. Access Persons must receive the prior clearance of the Chairperson of the Ethics Committee or his or her designee before forming or participating in a stock or investment club. Transactions in which Access Persons have beneficial ownership or control (defined on page 5-4) through investment clubs are subject to the firm's Statement of Policy on Securities Transactions. Approval to form or participate in a stock or investment club may permit the execution of securities transactions without prior transaction clearance by the Access Person, except transactions in Price Group stock, if the Access Person has beneficial ownership solely by virtue of his or her spouse's participation in the club and has no investment control or input into
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decisions regarding the club's securities transactions. Non-Access Persons (defined on page 5-4) do not have to receive prior clearance to form or participate in a stock or investment club and need only obtain prior clearance of transactions in Price Group stock.
Marketing and Sales Activities. All written and oral sales and marketing materials and presentations must be in compliance with applicable SEC, FINRA, Global Investment Performance Standards ("GIPS"), FCA, and other applicable international requirements. All such materials (whether for the Price Funds, other commingled investment vehicles, non-Price funds, or various advisory or Brokerage services) must be reviewed and approved by the Legal Department's Global Communications Compliance Team, as appropriate, prior to use. All performance data distributed outside the firm, including total return and yield information, must be obtained from databases sponsored by the Performance Group.
Outside Business Activities. Please refer to Conflicts of Interest (page 2-4).
Past and Current Litigation and Inquiries from Regulators or Governmental Organizations. As a condition of employment, each new employee is required to provide information regarding past and current civil (including arbitrations) and criminal actions and certain regulatory matters. Price Group uses the information obtained to respond to questions asked on governmental, regulatory, and self-regulatory registration forms and for insurance and bonding purposes.
Each employee is responsible for keeping responses pertaining to past and current civil (including arbitrations) and criminal actions and certain regulatory matters updated (notify Code Compliance). An employee should notify Human Resources and either the Legal Department or the International Compliance Team promptly if he or she:
∙Becomes the subject of any proceeding or is convicted of or pleads guilty or no contest to or agrees to enter a pretrial diversion program relating to any felony or misdemeanor or similar criminal charge in a U.S. (federal, state, or local), foreign or military court,
∙Becomes the subject of a Regulatory Action, which includes any action initiated by a securities regulator (e.g. Securities and Exchange Commission (U.S.), Financial Conduct Authority (UK), Securities and Futures Commission of Hong Kong, etc.), or
∙Receives an inquiry from any regulator or governmental authority.
Political Activities and Contributions. Price Group and its subsidiaries as well as their employees are subject to various federal, state and local laws regarding political contributions. These regulations can restrict the ability of the firm and its employees to make political contributions. In particular, the SEC has adopted Rule 206(4)-5 of the Advisers Act, known as the "Pay-To-Play" rule. The rule was adopted to address pay-to-play practices under which direct or indirect payments by investment advisers, and certain of their executive or employees, to state and local government officials in the U.S. may be perceived to improperly influence the award of government investment business. Generally, the rule prohibits an investment adviser from providing advisory services for compensation to a government entity client for two years after the adviser or certain of its executives or employees make a contribution over a de minimis amount to certain elected officials or candidates. The rule affects T. Rowe Price and its employees because government entities use the firm's advisory services and also invest in T. Rowe Price mutual funds.
The firm has adopted a "Statement of Policy Regarding Political Contributions" ("Political
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Contributions Policy" or "Policy") to comply with the SEC rule and other applicable laws and requirements. Under the Policy, all T. Rowe Price employees globally are required to prior clear proposed political contributions, as defined in the Policy, to any candidate, officeholder, political party, Political Action Committee ("PAC"), political organization, or bond ballot campaign in the U.S. Note that employees must separately ensure that they are eligible by applicable law to make the contribution at issue; for example, U.S. law generally permits only U.S. citizens and "green card" holders to contribute to federal, state, and local elections. Employees are generally prohibited from coordinating, or soliciting third parties to make, a contribution or payment to any candidate, officeholder, political party, PAC, political organization, or bond ballot campaign in the U.S. Additionally, employees are prohibited from doing anything indirectly that, if done directly, would violate this Policy. Any questions about the Political Contributions Policy should be directed to the "Political Contribution Requests" mailbox.
In addition to the requirements imposed by the SEC rule, all U.S.-based officers and directors of Price Group and its subsidiaries are required to disclose certain Maryland local and state political contributions on a semi-annual basis and certain Pennsylvania political contributions on an annual basis. Certain employees associated with Investment Services are subject to limitations on and additional reporting requirements about their political contributions under Rule G-37 of the U.S. Municipal Securities Rulemaking Board ("MSRB"). Furthermore, the firm and/or some employees are subject to additional restrictions because of client contractual stipulations.
U.S. law prohibits corporate contributions to campaign elections for federal office (e.g., U.S. Senate and House of Representatives). The SEC rule effectively prohibits corporate contributions by the firm to state and local elections.
No political contribution of corporate funds, direct or indirect, to any political candidate or party, or to any other program that might use the contribution for a political candidate or party, or use of corporate property, services or other assets may be made without the written prior approval of the Legal Department. These prohibitions cover not only direct contributions, but also indirect assistance or support of candidates or political parties through purchase of tickets to special dinners or other fundraising events, or the furnishing of any other goods, services or equipment to political parties or committees. Neither Price Group nor its employees or independent directors may make a political contribution for the purpose of obtaining or retaining business with government entities.
T. Rowe Price does not reimburse employees for making contributions to individual candidates or committees. Additionally, the firm cannot provide paid leave time to employees for political campaign activity. However, employees may use personal time or paid vacation or may request unpaid leave to participate in political campaigning.
T. Rowe Price does not have a PAC. However, T. Rowe Price has granted permission to the Investment Company Institute's PAC ("ICI PAC"), which serves the interests of the Investment company industry, to solicit T. Rowe Price's senior management on an annual basis to make contributions to ICI PAC or candidates designated by ICI PAC. Contributions to ICI PAC are entirely voluntary. Additionally, proposed contributions to the ICI PAC must go through the prior clearance process.
As noted above, the SEC rule prohibits most solicitation activities. To the extent the Legal Department approves solicitation activities in accordance with applicable rules or other requirements employees, officers, and directors of T. Rowe Price may not solicit campaign
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contributions from employees without adhering to T. Rowe Price's policies regarding solicitation. These include the following:
∙It must be clear that the solicitation is personal and is not being made on behalf of T. Rowe Price.
∙It must be clear that any contribution is entirely voluntary.
∙T. Rowe Price's stationery and email system may not be used.
An employee who wants to participate in political campaigns or run for political office should consult with his or her immediate supervisor to make sure that this activity does not conflict with his or her job responsibilities. Also, the employee should contact the Legal Department to discuss any activities which may be prohibited.
Lobbying. It is important to realize that under some state laws, even limited contact, either in person or by other means, with public officials in that state may trigger that state's lobbying laws. For example, in Maryland, if $2,500 of a person's compensation can be attributed to face-to-face contact with legislative or executive officials in a six-month reporting period, he or she may be required to register as a Maryland lobbyist subject to a variety of restrictions and requirements. Therefore, it is imperative that you avoid any lobbying on behalf of the firm, whether in-person or by other means (e.g., telephone, letter) unless the activity is cleared first by the Legal Department, so that you do not inadvertently become subject to regulation as a lobbyist. If you have any question whether your contact with a state's officials may trigger lobbying laws in that state, please contact the Legal Department before proceeding.
Professional Designations. It is the supervisor's responsibility to confirm that any designation (CFA, CFP, etc.) used by his or her direct reports in connection with T. Rowe Price business, including its use, is a valid designation issued by a reputable credentialing organization. In addition, the supervisor must take reasonable steps to confirm that the associate has earned the designation; it is relevant to his or her job and is authorized to use it. It is the responsibility of the associate to comply with the professional standards and reporting obligations of the organization that administers and authorizes the use of the professional designation. Any questions should be directed to the Legal Department.
Protection of Corporate Assets. All personnel are responsible for taking measures to ensure that Price Group's assets are properly protected. This responsibility not only applies to our business facilities, equipment and supplies, but also to intangible assets such as proprietary research or marketing information, corporate trademarks and service marks, copyrights, client relationships, and business opportunities. Accordingly, you may not solicit for your personal benefit clients or utilize client relationships to the detriment of the firm. Similarly, you may not solicit co-workers to act in any manner detrimental to the firm's interests.
Quality of Services. It is a continuing policy of Price Group to provide investment products and services that meet applicable laws, regulations and industry standards, are offered to the public in a manner that ensures that each client/shareholder understands the objectives of each investment product selected, and are properly advertised and sold in accordance with all applicable SEC, FCA, FINRA, and other international, state and self-regulatory rules and regulations.
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The quality of Price Group's investment products and services and operations affects our reputation, productivity, profitability, and market position. Price Group's goal is to be a quality leader and to create conditions that allow and encourage all employees to perform their duties in an efficient, effective manner.
Record Retention and Destruction. Under various U.S., UK, other international, state, and other governmental laws and regulations, certain of Price Group's subsidiaries are required to produce, maintain and retain various records, documents and other written (including electronic) communications. Different requirements can apply depending on the type of records, for example client-related records as opposed to HR-related records or general business records. Any questions regarding retention requirements should be addressed to the Legal Department or the TRP International Compliance Team.
You must use care in disposing of any confidential records or correspondence. Confidential material that is to be discarded should be placed in designated bins or should be shredded, as your department requires. If a quantity of material is involved, you should contact Document Management for instructions regarding proper disposal. Documents stored off-site are destroyed on a regular basis if the destruction is approved by the appropriate business contact.
Generally, there can be legal prohibitions from destroying any existing records that may be relevant to any current, pending or threatened litigation, or regulatory investigation or audit. These records would include emails, calendars, memoranda, board agendas, recorded conversations, studies, work papers, computer notes, handwritten notes, telephone records, expense reports, or similar material. If your business area is affected by litigation or an investigation or audit, you can expect to receive instructions from the Legal Department on how to proceed. Regardless of whether you receive such instructions, you should be prepared to secure relevant records once you become aware that they are subject to litigation or regulatory investigations or audits.
All personnel are responsible for adhering to the firm's record maintenance, retention, and destruction policies.
Referral Fees. U.S. securities laws strictly prohibit the payment of any type of referral fee unless certain conditions are met. This would include any compensation to persons who refer clients or shareholders to T. Rowe Price (e.g., brokers, registered representatives, consultants, or any other persons) either directly in cash, by fee splitting, or indirectly by the providing of gifts or services (including the allocation of brokerage). The FCA also prohibits the offering of any inducement likely to conflict with the duties of the recipient. No arrangements should be entered into obligating Price Group or any employee to pay a referral fee unless approved first by the Legal Department.
Release of Information to the Press. All requests for information from the media concerning T. Rowe Price Group's corporate affairs, mutual funds, investment services, investment philosophy and policies, and related subjects should be referred to the appropriate Corporate Communications/Public Relations contact for reply. Investment professionals who are contacted directly by the press concerning a particular fund's investment strategy or market outlook may use their own discretion but are advised to check with the appropriate Corporate Communications/Public Relations contact if they do not know the reporter or feel it may be inappropriate to comment on a particular matter. Please refer to the Global Media Engagement Guidelines located on the Exchange for additional information.
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Responsibility to Report Violations. The following is a description of reporting requirements and procedures that may or do arise if an officer or employee becomes aware of material violations of the Code or applicable laws or regulations.
General Obligation. If an officer or employee becomes aware of a material violation of the Code or any applicable law or regulation, he or she must report it to the Chief Compliance Officer of the applicable Price Adviser ("Chief Compliance Officer") or his or her designee, provided the designee provides a copy of all reports of violations to the Chief Compliance Officer. Reports submitted in paper form should be sent in a confidential envelope. Any report may be submitted anonymously; anonymous complaints must be in writing and sent in a confidential envelope to the Chief Compliance Officer. Officers and employees may also contact any governmental and/or regulatory authority (e.g. SEC and FINRA in the U.S., FCA in the UK, SFC in Hong Kong, etc.).
Global Whistleblower Procedures. Price Group has adopted procedures for associates to report potential or actual violations of laws and regulations in each of the jurisdictions in which it operates. The procedures outline steps associates can take to report matters internally to the Legal Department, or on an anonymous basis through the Whistleblower Hotline, or externally to a regulatory authority. The procedures are located in the firm's policy and procedures repository.
It is Price Group's policy that no adverse action will be taken against any person as a result of that person becoming aware of a violation of the Code and reporting the violation in good faith.
Sarbanes-Oxley Whistleblower Procedures. Pursuant to the Sarbanes-Oxley Act, the Audit Committee of Price Group has adopted procedures ("Procedures") regarding the receipt, retention and treatment of complaints received by Price Group regarding accounting, internal accounting controls or auditing matters and the confidential, anonymous submission by employees of Price Group or any of its affiliates of concerns regarding questionable accounting or auditing matters. All employees should familiarize themselves with these Procedures, which are posted in the firm's policies and procedures repository.
Under the Procedures, complaints regarding certain auditing and accounting matters should be sent to Chief Legal Counsel, T. Rowe Price Group, Inc., The Legal Department either through interoffice mail in a confidential envelope or by mail marked confidential to P.O. Box 37283, Baltimore, Maryland 21297-3283, or a report may be made by calling the toll- free hotline at 888-651-6223.
Sarbanes-Oxley Attorney Reporting Requirements. Attorneys employed or retained by Price Group or any of the Price Funds are also subject to certain reporting requirements under the Sarbanes-Oxley Act. The relevant procedures are posted in the firm's policies and procedures repository.
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Circulation of Rumors. Individuals subject to the Code shall not originate or circulate in any manner a rumor concerning any security which the individual knows or has reasonable grounds for believing is false or misleading or would improperly influence the market price of that security. You must promptly report to the Legal Department any circumstance which would reasonably lead you to believe that such a rumor might have been originated or circulated.
Service as Trustee, Executor or Personal Representative. You may serve as the trustee, co- trustee, executor or personal representative for the estate of or a trust created by close family members. You may also serve in such capacities for estates or trusts created by nonfamily members. However, if an Access Person expects to be actively involved in an investment capacity in connection with an estate or trust created by a nonfamily member, he or she must first be granted permission by the Ethics Committee. If you serve in any of these capacities, securities transactions affected in such accounts will be subject to the prior transaction clearance (Access Persons only, except for Price Group stock transactions, which require prior transaction clearance by all personnel) and reporting requirements (Access Persons and Non-Access Persons) of our Statement of Policy on Securities Transactions. If you presently serve in any of these capacities for non- family members, you should report the relationship in writing to the Ethics Committee.
Speaking Engagements and Publications. Employees are often asked to accept speaking engagements on the subject of investments, finance, or their own particular specialty with our organization. This is encouraged by the firm as it enhances our public relations. You should obtain approval from your supervisor and Division Head before you accept such requests. You may also accept an offer to teach a course or seminar on investments or related topics (for example, at a local college) in your individual capacity with the approval of your supervisor and Division Head, provided the course is in compliance with the Guidelines found in T. Rowe Price Investment Services' Compliance Manual. Before making any commitment to write or publish any article or book on a subject related to investments or your work at Price Group, approval should be obtained from your supervisor and Division Head.
Social Media. As T. Rowe Price associates, anything we say or do in our personal communications, including on social media, can reflect on T. Rowe Price's brand and reputation. We should be aware of this when making personal posts and remember that nothing we say in the social media space is totally private and, in fact, may be available indefinitely.
While T. Rowe Price does not discourage associates from using social media to maintain personal connections, it is important to understand what is acceptable and prohibited when using social media. The T. Rowe Price Policy for Associate Use of Social Media, available on the Exchange, sets forth the permissible use of social media, whether for personal or business use, by T. Rowe Price associates. Examples of permissible and impermissible actions include:
∙Do not discuss work or specific projects or products on any social network account;
∙Do not post any information about T. Rowe Price products, services, competitors, business contacts, or other associates without prior authorization and training;
∙Do not respond to questions or comments about T, Rowe Price products or services without prior authorization and training;
∙Do not comment on any individual posts;
∙Associates can share any T. Rowe Price job vacancy listed on the T. Rowe Price Careers site or LinkedIn Jobs page on the network of their choice;
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∙Associates can "like" or "follow" T. Rowe Price social media pages; and
∙Associates can only "like" and share individuals posts that have been identified as approved for associate interaction.
The policy applies whether or not associates are on company premises and whether or not associates are using a T. Rowe Price system, T. Rowe Price-issued device, or personal device. The policy is designed to provide associates with clear direction when using social media to ensure the firm's compliance with applicable regulations when engaging in social media channels, and to protect our associates, our clients, and the company.
Systems Security. Computer systems and programs play a central role in Price Group's operations. To establish appropriate systems security to minimize potential for loss or disruptions to our computer operations, Price Group has adopted a Statement of Policy on Systems Security and Related Issues (page 6-30).
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T. ROWE PRICE GROUP, INC.
STATEMENT OF POLICY
ON
GIFTS AND BUSINESS ENTERTAINMENT
T. Rowe Price adopted this policy to govern the receipt and giving of gifts and business entertainment by all employees of T. Rowe Price globally ("Associates"). The giving and receiving of gifts and business entertainment must be carefully considered by Associates to avoid even the appearance of conflicts of interest.
Associates are encouraged to ask for guidance about how to apply this policy in advance of giving or receiving a gift or business entertainment. Questions can be directed to your manager or to the Legal Department.
The Code and laws in numerous jurisdictions regulate gifts and entertainment to ensure that such practices do not constitute the direct or indirect provision or receipt of bribes, kickbacks, quid pro quos, or other corrupt practices. Please refer to the "Foreign Corrupt Practices Act and Other Illegal Payments" section of the Code and the firm's "Compliance Policy and Program Statement Relating to Anti-Bribery Laws and Prohibitions Against Illegal Payments."
Specific controls are applicable to ERISA plans and certain other regulatory regimes see "Jurisdictions and Specific Requirements" section.
Gifts
The term "gift" has a broad meaning, including merchandise, gratuities and the use of property or facilities for weekends, vacations, and trips, including transportation and lodging costs, but does not include items of nominal value (defined later in this policy).
General rules for all Associates:
∙You may not give gifts in excess of US$100 (aggregate annual limit per business contact). You may not receive gifts in excess of US$100 (aggregate annual limit per organization). Please note that gifts given to a business contact's family member (e.g., spouse or children) will count towards the US$100 annual gift limit for that business contact.
∙You may not accept gifts from broker-dealers.
∙You may not give gifts to or receive gifts from a vendor, client, prospect, or a lead manager of a consultant who has active negotiations or Requests for Proposals
("RFPs") for services or products.
∙Any gift, given or received, must be reported.
∙Gifts may never be given or received in consideration of any business or transaction, or in connection with the purchase or sale of client securities or other investments.
∙Gifts of cash or cash equivalents may not be given or received.
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Items of Nominal Value
Other than as noted in the Jurisdictions and Specific Requirements section of this policy, the term "gift" as described in this policy does not include an item of nominal value. Items with a value of US$50 or less are regarded as nominal items. For example, items such as pens, notepads, modest desk ornaments, or items that display the giving firm's logo, which are typically given out at conferences or elsewhere, would generally fall within this exclusion. If an item is to be given in connection with the broker-dealer's business, its value must not exceed US$50 and the item must have the TRP corporate logo permanently affixed to be exempt from the definition of "gift."
Personal Gift Exclusion
A personal gift given or received in recognition of a "life event" such as a baby or wedding gift, does not fall within this policy provided the gift is not "in relation to the business of the employer of the recipient." There should be a pre-existing personal or family relationship between the giver and the recipient. The giver, not the firm, should pay for the gift. In addition, if an Associate is giving a gift in recognition of a life event, the giver must obtain prior approval from his/her supervisor, Business Unit Head if different, and the Chairperson of the Ethics Committee. If these conditions are met, the recordkeeping requirements and the US$100 limit do not apply.
Gifts Received by Attendees at an Event
Any gift or gifts received by Associates at an event (e.g., industry conference, vendor user conference, investor relations event, etc.), other than nominal gifts (see above), must be reported and the total value cannot exceed the US$100 gift limit. If an event provides a gift or gifts with a value greater than US$100, Associates may decline to accept the gift, donate it to charity or, with the approval of the Chairperson of the Ethics Committee, present the gift to the Associate's Business Unit for a random draw of an identified group of associates of an appropriate size.
Group Gifts
When a group gift valued at up to US$100 (e.g., chocolate assortment) is sent by a T. Rowe Price Associate, the gift report must identify the name of at least one business contact at the receiving organization. If an Associate or a T. Rowe Price department receives a gift that is valued in excess of the US$100 limit, it can be shared amongst Associates provided no single Associate's share of the gift exceeds the US$100 limit. Alternatively, with the approval of the Chairperson of the Ethics Committee, the gift can be awarded to the winner of a random draw of an identified group of associates of an appropriate size or donate it to charity.
Recurring Gifts
Tickets or other gifts (including nominal value items) may not be given nor accepted from a business contact or firm on a standing, recurring, or ongoing basis. Supervisors are responsible for monitoring how frequently their Associates receive and give gifts to/from specific business contacts to avoid potential conflicts of interest.
Calculation of Value
Gifts should be valued at the cost paid by the giver. Associates and Managers should be mindful that if the market value of a gift is materially greater than the cost, consultation with the Legal Department may be appropriate to determine if another value should be used.
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Business Entertainment
Entertainment must serve a legitimate and appropriate business purpose ("Business Entertainment"). Generally, business entertainment includes meals and sporting events with business contacts (e.g., clients or vendors). Associates should be mindful that business entertainment should generally not be solicited and only accepted after an invitation from your host. Both the Associate and the business contact must be in attendance for an event to be classified as business entertainment. Business entertainment should not be so frequent or so lavish with the same business contact or client, that when viewed in its entirety, it could be viewed as a potential conflict of interest. See "Jurisdictions and Specific Requirements" for additional restrictions on Business Entertainment.
Reporting and Prior Clearance
1.Business entertainment valued above US$100 per person must be reported.
2.Business entertainment that exceeds US$250 per person requires prior approval by the
Associate's Manager and either the Business Unit Head or Region/Segment Head (as determined by the Business Unit).
3.Broker-dealer provision: All meal business entertainment received from broker-dealers above US$100 per person requires prior approval by the Associate's Manager and must be reported. All non-meal business entertainment received from broker-dealers, regardless of value, requires prior approval by the Associate's Manager and must be reported. T. Rowe Price (or in some cases, the Associate) will pay or reimburse the broker-dealer for such reported business entertainment.
4.Business entertainment that includes a guest (e.g., spouse or child) requires prior approval by the Associate's Manager and either the Business Unit Head or Region/Segment Head (as determined by the Business Unit). Keep in mind that the Associate may need to pay for the cost of the guest.
5.Business entertainment that does not occur in the normal course of business or is an event of national prominence requires prior approval by the Associate's Manager and either the
Business Unit Head or Region/Segment Head (as determined by the Business Unit).
6.Business entertainment may never be given or received in consideration of any business or transaction, or in connection with the purchase or sale of client securities or other investments.
Each Business Unit will implement procedures to assess and consider relevant factors when determining if approval should be granted in the circumstances requiring prior approval. For example, factors may include the purpose of the meeting, the nature of the event being conducive to conversation, the exclusivity of the event, the frequency of interaction with the business contact and whether T. Rowe Price or the Associate should be bearing some portion or all of the associated cost.
Post-Event Approval
In certain situations, an Associate may not be able to ascertain the cost of an event until after its conclusion, such as business dinners. In the event the business entertainment was expected to be 3-3
within these reporting thresholds (e.g., less than US$250 per person) but unexpectedly exceeds them, the Associate must promptly report such entertainment to his/her Manager for further discussion. In these limited circumstances and after review by the Associate's Manager, "post- event" approval by a Region/Segment Head or Business Unit Head (as determined by the Business Unit) will be considered to be in compliance with this policy.
Transportation and Lodging
Generally, the cost of transportation and lodging expenses associated with business entertainment should be borne by the party using the transportation or lodging. Ordinary ground transportation such as a taxi ride or a courtesy shuttle is not subject to this restriction.
Active RFPs/Business Transactions
Associates may not entertain key decision makers of a vendor, prospect or current client (or their lead manager consultant) with an active RFP or where material negotiations of specific business or transactions are taking place. Key decision makers are those individuals who have significant influence on the decision related to the RFP or transaction which would include an ERISA plan fiduciary representative. However, meals closely associated with substantive business meetings (i.e., plan reviews, due diligence visits, investment reviews, educational sessions) are permitted.
Large-Scale Events
The cost-per-individual at an event (e.g., industry conference, vendor user conference, investor relations event) is not counted towards US$250 prior approval threshold provided that the conference has a reasonable relationship to the duties of the attending Associate(s) and the expenses for attendance are reasonable in light of the benefits afforded to the firm by such attendance. Associates should keep in mind that if there are separate excursions or other entertainment connected with the large-scale event (e.g., golf outings, boating trips, etc.) then the reporting and prior clearance requirements will apply to these separate events.
Calculation of Value
Business entertainment should be valued at the cost paid by the giver. Associates and Managers should be mindful that if the market value of an event is materially greater than the cost, consultation with the Legal Department may be appropriate to determine if another value should be used.
Jurisdictions and Specific Requirements
In addition to the general gift and entertainment rules in this policy, certain jurisdictions or regulators may impose restrictions that are more stringent than the general provisions of this policy. Associates that work in a jurisdiction outside of their primary office jurisdiction are subject to the rules of the jurisdiction with the higher standards. The following sets forth a summary of those restrictions.
TRPIL and Its European Subsidiaries Associates: UK FCA Inducements Rules and Guidance
The FCA Conduct of Business rules requires that gifts and entertainment provided or received must not impair our ability to act in the best interests of our clients. Guidance issued by the FCA notes that business entertainment in the form of sporting events or other social events may not be considered as capable of enhancing the quality of service to clients as they may either not be
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conducive to business discussions or the discussions could better take place without these activities. The following additional policy requirements apply to T. Rowe Price International Ltd ("TRPIL") and its European subsidiaries:
Business Entertainment: All non-meal business entertainment provided or received, regardless of value, and regardless of whether it is provided by a broker-dealer or to or from other third-party business contacts, requires prior approval by the associate's manager and must be reported. T. Rowe Price (or in some cases, the associate) will pay or reimburse the donor for such reported business entertainment.
In determining approval, the associates' manager must consider whether the non-meal entertainment is capable of enhancing the quality of service to the client. Spectating at a sporting event or attending a concert or the theatre will not generally be considered to enhance the quality of service to the client and cannot generally therefore be accepted from or given to a third party. Participatory events such as a round of golf may be acceptable upon demonstration by the associate that the event is both conducive to business discussions and ultimately benefits our client. The approval must be clearly documented.
While the reimbursement to the business contact (by T. Rowe Price or the associate) removes the key inducement, there is possibly an intrinsic value in the invitation to an event in that it may not be available to the general public due to its popularity, the associate must be able to clearly demonstrate that the full market value is reimbursed to the business contact in order for their manager to approve.
U.S. - ERISA Covered Plans: US$250 Annual Limit
In accordance with guidance from the U.S. Department of Labor, the annual limit in this policy on gifts and business entertainment provided to an ERISA plan fiduciary representative (including plan advisers serving in a fiduciary capacity) is US$250. All gifts and business entertainment provided to a fiduciary business contact count towards this US$250 annual limit and must be prior approved by the Associate's Manager or Region/Segment Head (as determined by the Business Unit) to help ensure the annual limit is not exceeded, except as provided below. Note that all gifts and business entertainment provided to a fiduciary business contact are subject to this policy's reporting and prior clearance rules, even if not counted towards the US$250 annual limit.
1.Meals provided by Associates to fiduciary business contacts at educational conferences, including T. Rowe Price hosted conferences; do not count towards the US$250 annual limit.
2.Meals and entertainment provided at educational conferences hosted by T. Rowe Price do not count towards the US$250 annual unit. Note that fiduciary business contacts may be subject to rules pertaining to their acceptance of meals and entertainment at such events. Consult with the Compliance Manager/SME within your business unit to determine your business unit guidelines for reminding recipients of these rules.
3.Meals provided to fiduciary business contacts and closely associated with substantive business meetings (e.g., plan reviews, due diligence visits, investment reviews, educational sessions) do not count towards the US$250 annual limit.
4.Expenses for ordinary ground transportation such as taxi ride or courtesy shuttle that are closely associated with a substantive business meeting or an educational conference do not
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count towards the US$250 annual limit. Transportation expenses associated with relationship- building and other forms of entertainment would count towards the US$250 annual limit.
5.Items of nominal value given to fiduciary business contacts are not subject to this policy's reporting requirements and do not count towards the US$250 annual limit. Generally, items that are less than US$10 are deemed to have nominal value. For the avoidance of doubt, any item that has a value greater than US$10, including items with a corporate logo permanently affixed, count towards the US$250 annual limit and must be reported.
6.Meals and entertainment provided by a Business Unit Head to a fiduciary business contact for purposes of obtaining market intelligence (and not to support sales activity) do not count towards the US$250 annual limit.
Note that all gifts, business entertainment, and meals given to or attended by guests of the fiduciary business contact(s) (including in the context of an educational conference) count towards the US$250 annual limit for the fiduciary and are subject to this policy's reporting and prior clearance rules.
Providing services or support (including some types of marketing support) to an ERISA plan fiduciary may be considered a gift. Consult with the Compliance Manager/SME within your business unit for assistance in evaluating whether such services or support would be subject to this policy.
Country and U.S. State Specific Requirements
Countries and U.S. states may adopt rules that govern the provision of gifts and business entertainment. Such rules may impose strict dollar limits or prohibitions on providing gifts and business entertainment which may be more restrictive than this policy. Additionally, these rules may impose increased reporting requirements on Associates. The Legal Department will work with business units to inform them of these jurisdictions' specific rules.
Reporting
It is ultimately the Associate's responsibility to properly report gifts and business entertainment, whether given or received, in accordance with each business unit's reporting procedures. All gifts must be reported within ten business days. All business entertainment must be reported promptly.
All gifts and business entertainment reports will be available for review by Legal & Compliance, including International Compliance, in conjunction with their responsibility to oversee our firm- wide compliance.
The U.S. Department of Labor has established strict gift and entertainment reporting rules relative to ERISA clients. All gifts and business entertainment of US$10 or more accepted from, provided to, or in relation to ERISA clients should be reported under the Associate's business unit's procedures.
Chair of the Ethics Committee
Special circumstances may arise that would require the review of the Chair of the Ethics Committee and may result in exceptions being granted to part or all of this policy.
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T. ROWE PRICE GROUP, INC.
STATEMENT OF POLICY
ON
MATERIAL, INSIDE (NON-PUBLIC) INFORMATION
Policy of Price Group on Insider Trading. It is the policy of Price Group and its affiliates to forbid any of their officers, directors, employees, or other personnel (e.g., consultants) while in possession of material, non-public information, from trading securities or recommending transactions, either personally or in their proprietary accounts or on behalf of others (including mutual funds and private accounts) or communicating material, non-public information to others in violation of securities laws of the U.S., the UK, or any other country that has jurisdiction over its activities. Material, non-public information includes not only certain information about issuers, but also certain information about T. Rowe Price Group, Inc. and its operating subsidiaries as well as information pertaining to Price Funds and clients.
Purpose of Statement of Policy. As a global firm, Price Group is subject to a wide array of laws and regulations that prohibit the misuse of inside information. The purpose of this Statement of Policy ("Statement") is to describe and explain: (i) the general legal prohibitions and sanctions regarding insider trading under U.S. and global regulations and how they are applicable across the firm globally; (ii) the meaning of the key concepts underlying the prohibitions; (iii) your obligations in the event you come into possession of material, non-public information; and (iv) the firm's educational program regarding insider trading. Additionally, the U.S. Insider Trading and Securities Fraud Enforcement Act ("Act") requires Price Group to establish, maintain, and enforce written procedures designed to prevent insider trading.
Many jurisdictions, including Hong Kong, Singapore, Japan, Australia and most European countries, have laws and regulations prohibiting the misuse of inside information. While this Statement does not make specific reference to these laws and regulations, the Statement provides general guidance regarding appropriate activities that is applicable to all employees globally. There is, however, no substitute for knowledge of local laws and regulations. Employees are expected to understand the relevant local requirements where they work and comply with them. Any questions regarding the laws or regulations of any jurisdiction should be directed to the Legal Department or the TRP International Compliance Team.
The Basic Insider Trading Prohibition. The "insider trading" doctrine under U.S. securities laws generally prohibits any person (including investment advisers) from:
∙Trading in a security while in possession of material, non-public information regarding the issuer of the security;
∙Tipping such information to others;
∙Recommending the purchase or sale of securities while in possession of such information;
∙Assisting someone who is engaged in any of the above activities.
Thus, "insider trading" is not limited to insiders of the issuer whose securities are being traded. It can also apply to non-insiders, such as investment analysts, portfolio managers, consultants and stockbrokers. In addition, it is not limited to persons who trade. It also covers persons who tip material, non-public information or recommend transactions in securities while in possession of
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such information. A "security" includes not just equity securities, but any security (e.g., corporate and municipal debt securities, including securities issued by the federal government).
"Need to Know" Policy. All information regarding planned, prospective or ongoing securities transactions must be treated as confidential. Such information must be confined, even within the firm, to only those individuals and departments that must have such information in order for the respective entity to carry out its engagement properly and effectively. Ordinarily, these prohibitions will restrict information to only those persons who are involved in the matter.
Transactions Involving Price Group Stock. You are reminded that you are an "insider" with respect to Price Group since Price Group is a public company and its stock is traded on the NASDAQ Stock market. It is therefore important that you not discuss with family, friends or other persons any matter concerning Price Group that might involve material, non-public information, whether favorable or unfavorable. You are prohibited from trading Price Group stock (TROW) if you are privy to material, non-public information.
Sanctions. Penalties for trading on material, non-public information are severe, both for the individuals involved in such unlawful conduct and for their firms. A person or entity that violates the insider trading laws can be subject to some or all of the penalties described below, even if he/she/it does not personally benefit from the violation:
∙Injunctions;
∙Treble damages;
∙Disgorgement of profits;
∙Criminal fines;
∙Jail sentences;
∙Civil penalties for the person who committed the violation (which would, under normal circumstances, be the employee and not the firm); and
∙Civil penalties for the controlling entity (e.g., Price Associates) and other persons, such as managers and supervisors, who are deemed to be controlling persons.
In addition, any violation of this Statement can be expected to result in serious sanctions being imposed by Price Group, including dismissal of the person(s) involved. The provisions of U.S. and UK law discussed below, and the laws of other jurisdictions are complex and wide ranging. If you are in any doubt about how they affect you, you must consult the Legal Department or the TRP International Compliance Team, as appropriate.
U.S LAW AND REGULATION REGARDING INSIDER TRADING PROHIBITIONS
Introduction. "Insider trading" is a top enforcement priority of the U.S. Securities and Exchange Commission. The Insider Trading and Securities Fraud Enforcement Act has far-reaching impact on all public companies and especially those engaged in the securities brokerage or investment advisory industries, including directors, executive officers and other controlling persons of such companies. Specifically, the Insider Trading and Securities Fraud Enforcement Act:
Written Procedures. Requires SEC-registered brokers, dealers and investment advisers to establish, maintain and enforce written policies and procedures reasonably designed to prevent the misuse of material, non-public information by such persons.
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Penalties. Imposes severe civil penalties on brokerage firms, investment advisers, their management and advisory personnel, and other "controlling persons" who fail to take adequate steps to prevent insider trading and illegal tipping by employees and other "controlled persons." Additionally, the Act contains substantial criminal penalties, including monetary fines and jail sentences.
Private Right of Action. Establishes a statutory private right of action on behalf of contemporaneous traders against insider traders and their controlling persons.
Bounty Payments. Authorizes the SEC to award bounty payments to persons who provide information leading to the successful prosecution of insider trading violations. Bounty payments are at the discretion of the SEC but may not exceed 10 30% of the penalty imposed.
The Act has been supplemented by three SEC rules, 10b5-1, 10b5-2 and Fair Disclosure, which are discussed later in this Statement.
Basic Concepts of Insider Trading. The four critical concepts under U.S. law in insider trading cases are: (1) fiduciary duty/misappropriation, (2) materiality, (3) non-public and (4) use/possession. Each concept is discussed below.
Fiduciary Duty/Misappropriation. In two decisions, the U.S. Supreme Court outlined when insider trading and tipping violate the federal securities law if the trading or tipping of the information results in a breach of duty of trust or confidence.
The concept of who constitutes an "insider" is broad. It includes officers, directors, and employees of an issuer. In addition, a person can be a "temporary insider" if he or she enters into a confidential relationship in the conduct of an issuer's affairs and, as a result, is given access to information solely for the issuer's purpose. A temporary insider can include, among others, an issuer's attorneys, accountants, consultants, and bank lending officers, as well as the employees of such organizations. In addition, any person may become a temporary insider of an issuer if he or she advises the issuer or provides other services, provided the issuer expects such person to keep any material, non-public information confidential.
A typical breach of duty arises when an insider purchases securities of his or her corporation on the basis of material, non-public information. Such conduct breaches a duty owed to the corporation's shareholders. The duty breached, however, need not be to shareholders to support liability for insider trading; it could also involve a breach of duty to a client, an employer, employees, or even a personal acquaintance. For example, courts have held that if the insider receives a personal benefit (either direct or indirect) from the disclosure, such as a pecuniary gain or reputational benefit; that would be enough to find a fiduciary breach.
Court decisions have held that under a "misappropriation" theory, an outsider (such as an investment analyst) may be liable if he or she breaches a duty to anyone by: (1) obtaining information improperly, or (2) using information that was obtained properly for an improper purpose. For example, if information is given to an analyst on a confidential basis and the analyst uses that information for trading purposes, liability could arise under the misappropriation theory. Similarly, an analyst who trades in breach of a duty owed either to his or her employer or client may be liable under the misappropriation theory. For example, the Supreme Court upheld the
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misappropriation theory when a lawyer received material, non-public information from a law partner who represented a client contemplating a tender offer, where that lawyer used the information to trade in the securities of the target company.
SEC Rule 10b5-2 provides a non-exclusive definition of circumstances in which a person has a duty of trust or confidence for purposes of the "misappropriation" theory of insider trading. It states that a "duty of trust or confidence" exists in the following circumstances, among others:
(1)Whenever a person agrees to maintain information in confidence;
(2)Whenever the person communicating the material, nonpublic information and the person to whom it is communicated have a history, pattern, or practice of sharing confidences, that resulted in a reasonable expectation of confidentiality; or
(3)Whenever a person receives or obtains material, non-public information from his or her spouse, parent, child, or sibling unless it is shown affirmatively, based on the facts and circumstances of that family relationship, that there was no reasonable expectation of confidentiality.
The situations in which a person can trade while in possession of material, non-public information without breaching a duty are so complex and uncertain that the only safe course is not to trade, tip or recommend securities while in possession of material, non-public information.
Materiality. Insider trading restrictions arise only when the information that is used for trading, tipping or recommendations is "material." The information need not be so important that it would have changed an investor's decision to buy or sell; rather, it is enough that it is the type of information on which reasonable investors rely in making purchase, sale, or hold decisions.
Resolving Close Cases. The U.S. Supreme Court has held that, in close cases, doubts about whether or not information is material should be resolved in favor of a finding of materiality. You should also be aware that your judgment regarding materiality may be reviewed by a court or the SEC with the 20-20 vision of hindsight.
Effect on Market Price. Any information that, upon disclosure, is likely to have a significant impact on the market price of a security should be considered material. Future Events. The materiality of facts relating to the possible occurrence of future events depends on the likelihood that the event will occur and the significance of the event if it does occur.
Illustrations. The following list, though not exhaustive, illustrates the types of matters that might be considered material: a joint venture, merger or acquisition; the declaration or omission of dividends; the acquisition or loss of a significant contract; a change in control or a significant change in management; a call of securities for redemption; the borrowing of a significant amount of funds; the purchase or sale of a significant asset; a significant change in capital investment plans; a significant labor dispute or disputes with subcontractors or suppliers; an event requiring an issuer to file a current report on Form 8- K with the SEC; establishment of a program to make purchases of the issuer's own shares; a tender offer for another issuer's securities; an event of technical default or default on interest and/or principal payments; advance knowledge of an upcoming publication that is expected to affect the market price of the stock.
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Non-Public vs. Public Information. Any information that is not "public" is deemed to be "non- public." Just as an investor is permitted to trade on the basis of information that is not material, he or she may also trade on the basis of information that is public. Information is considered public if it has been disseminated in a manner making it available to investors generally. An example of non-public information would include material information provided to a select group of analysts but not made available to the investment community at large. Set forth below are a number of ways in which non-public information may be made public.
Disclosure to News Services and National Papers. The U.S. stock exchanges require exchange-traded issuers to disseminate material, non-public information about their company to: (1) the national business and financial newswire services (e.g. Bloomberg, Thomson Reuters, etc.); (2) the national service (Associated Press); and (3) The New York Times and The Wall Street Journal.
Local Disclosure. An announcement by an issuer in a local newspaper might be sufficient for an issuer that is only locally traded but might not be sufficient for an issuer that has a national market.
Information in SEC Reports. Information contained in reports filed with the SEC will be deemed to be public.
If Price Group is in possession of material, non-public information with respect to a security before such information is disseminated to the public (i.e., such as being disclosed in one of the public media described above), Price Group and its personnel must wait a sufficient period of time after the information is first publicly released before trading or initiating transactions to allow the information to be fully disseminated. Price Group may also follow Information Barrier procedures, as described on page 4-8 of this Statement.
Concept of Use/Possession. It is important to note that the SEC takes the position that the law regarding insider trading prohibits any person from trading in a security in violation of a duty of trust and confidence while in possession of material, non-public information regarding the security. This is in contrast to trading on the basis of the material, non-public information. To illustrate the problems created by the use of the "possession" standard, as opposed to the "caused" standard, the following three examples are provided:
First, if the investment committee to a Price mutual fund were to obtain material, non- public information about one of its portfolio companies from a Price equity research analyst, that fund would be prohibited from trading in the securities to which that information relates. The prohibition would last until the information is no longer material or non-public.
Second, if the investment committee to a Price mutual fund obtained material, non-public information about a particular portfolio security but continued to trade in that security, then the committee members, the applicable Price Adviser, and possibly management personnel might be liable for insider trading violations.
Third, even if the investment committee to the Fund does not come into possession of the material, non-public information known to the equity research analyst, if it trades in the security, it may have a difficult burden of proving to the SEC or to a court that it was not
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in possession of such information.
The SEC has expressed its view about the concept of trading "on the basis of" material, non-public information in Rule 10b5-1. Under Rule 10b5-1, and subject to the affirmative defenses contained in the rule, a purchase or sale of a security of an issuer is "on the basis" material non-public information about that security or issuer if the person making the purchase or sale was aware of the material, non-public information when the person made the purchase or sale.
A person's purchase or sale is not "on the basis of" material, non-public information if he or she demonstrates that:
(A)Before becoming aware of the information, the person had:
(1)Entered into a binding contract to purchase or sell the security;
(2)Instructed another person to purchase or sell the security for the instructing person's account, or
(3)Adopted a written plan for trading securities.
When a contract, instruction or plan is relied upon under this rule, it must meet detailed criteria set forth in Rule 10b5-1(c)(1)(i)(B) and (C).
Under Rule 10b5-1, a person other than a natural person (e.g., one of the Price Advisers) may also demonstrate that a purchase or sale of securities is not "on the basis of" material, non-public information if it demonstrates that:
∙The individual making the investment decision on behalf of the person to purchase or sell the securities was not aware of the information; and
∙The person had implemented reasonable policies and procedures, taking into consideration the nature of the person's business, to ensure that individuals making investment decisions would not violate the laws prohibiting trading on the basis of material, non-public information. These policies and procedures may include those that restrict any purchase, sale, and causing any purchase or sale of any security as to which the person has material, non-public information, or those that prevent such individuals from becoming aware of such information.
Tender Offers. Tender offers are subject to particularly strict regulation under the securities laws. Specifically, trading in securities that are the subject of an actual or impending tender offer by a person who is in possession of material, non-public information relating to the offer is illegal, regardless of whether there was a breach of fiduciary duty. Under no circumstances should you trade in securities while in possession of material, non-public information regarding a potential tender offer.
Selective Disclosure of Material, Non-Public Information by Public Companies. The SEC has adopted Regulation FD to prohibit certain issuers from selectively disclosing material, non-public information to certain persons who would be expected to trade on it. The rule applies only to publicly-traded domestic (U.S.) companies, not to foreign government or foreign private issuers.
Under this rule, whenever:
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∙An issuer, or person acting on its behalf,
∙Discloses material, non-public information,
∙To securities professionals, institutional investors, broker-dealers, and holders of the issuer's securities,
∙The issuer must make public disclosure of that same information,
∙Simultaneously (for intentional disclosures), or
∙Promptly within 24 hours after knowledge of the disclosure by a senior official (for non-intentional disclosures)
Regulation FD does not apply to all of the issuer's employees; rather only communication by an issuer's senior management (executive officers and directors), its investor relations professionals, and others who regularly communicate with market professionals and security holders are covered. Certain recipients of information are also excluded from the rule's coverage, including persons who are subject to a confidentiality agreement, credit rating agencies, and "temporary insiders," such as the issuer's lawyers, investment bankers, or accountants.
Expert Network Services. Expert networks may be used by approved investment staff to supplement the investment process. Expert networks provide investors with access to individuals having a particular expertise or specialization, such as industry consultants, vendors, doctors, attorneys, suppliers, or past executives of particular companies. Expert network services can be an important component of the investment research process, and Price Group has implemented various controls to govern these interactions. A strict approval process is in place for utilizing a new expert network service. Also, a reporting and oversight process exists in the Equity Division to ensure that the services are being used properly by only appropriate investment staff.
Information Regarding Price Group.
The illustrations of material information found on page 4-4 of this Statement are equally applicable to Price Group as a public company and should serve as examples of the types of matters that you should not discuss with persons outside the firm. Remember, even though you may have not intent to violate any federal securities law, an offhand comment to a friend might be used unbeknownst to you by such friend to effect purchases or sales of Price Group stock. If such transactions were discovered and your friend was prosecuted, your status as an informant or "tipper" would directly involve you in the case. If you have concerns or questions about whether certain information constitutes material, non-public information pertaining to Price Group you should contact the Legal Department.
Information Regarding T. Rowe Price Funds and Subadvised Funds.
Employees who possess material, non-public information pertaining to a Price Fund or subadvised fund are prohibited from trading in the shares of the fund. Associates may obtain or possess information about significant portfolio activity of a fund, such as an unscheduled disbursement or receipt that is not reflected in the fund's NAV, which could be regarded as material. For example, an associate may learn of a significant tax refund or litigation recovery that a fund is entitled to but has not been entered as a receivable because the amount and timing are unknown. Such information could constitute material, non-public information. Information regarding future events that would not be expected to have a known impact on the fund's NAV, such as a large
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subscription by an institutional shareholder or a change in the fund's portfolio manager, while considered highly sensitive information (not to be shared with others outside of T. Rowe Price), would not typically constitute material, non-public information for these purposes. If you have concerns or questions about whether certain information constitutes material, non-public information pertaining to a Price Fund or subadvised fund you should contact the Legal Department.
LAWS AND REGULATIONS REGARDING INSIDER TRADING PROHIBITIONS OUTSIDE THE U.S.
The jurisdictions outside the U.S. that regulate some T. Rowe Price entities have laws in this area that are based on principles similar to those of the U.S. described in this Statement. If you comply with the Code, then you will comply with the requirements of these jurisdictions. If you have any concerns about local requirements, please contact the TRP International Compliance Team or the Legal Department.
PROCEDURES TO BE FOLLOWED WHEN RECEIVING MATERIAL, NON-PUBLIC INFORMATION
Whenever you believe that you have or may have come into possession of material, non-public information, you should immediately contact the appropriate Legal Department person or group and refrain from disclosing the information to anyone else, including persons within Price Group, unless specifically advised to the contrary. The individual may not disclose the information or trade in the security until a determination is made by Legal. U.S.-based personnel should contact the Legal Department and international personnel should contact the International Compliance Team.
Specifically, you may not:
∙Trade in securities to which the material, non-public information relates;
∙Disclose the information to others;
∙Recommend purchases or sales of the securities to which the information relates.
If it is determined that the information is material and non-public, the issuer will be placed on either:
∙A Restricted List ("Restricted List") in order to prohibit trading in the security by both clients and Access Persons; or
∙A Watch List ("Watch List"), which restricts the flow of the information to others within
Price Group in order to allow the Price Advisers investment personnel to continue their ordinary investment activities. This procedure is commonly referred to as an Information Barrier.
The Watch List is highly confidential and should, under no circumstances, be disseminated to anyone except authorized personnel in the Legal Department and Code Compliance who are responsible for placing issuers on and monitoring trades in securities of issuers included on the Watch List. As described below, if an individual on the TRP International Compliance Team believes that an issuer should be placed on the Watch List, he or she will contact Code Compliance.
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Code Compliance will coordinate review of trading in the securities of that issuer with the TRP International Compliance Team as appropriate.
The person whose possession of or access to inside information has caused the inclusion of an issuer on the Watch List may never trade or recommend the trade of the securities of that issuer without the specific prior approval of the Legal Department.
The Restricted List is also highly confidential and should, under no circumstances, be disseminated to anyone outside Price Group. Individuals with access to the Restricted List should not disclose its contents to anyone within Price Group who does not have a legitimate business need to know this information.
Code Compliance will remove the issuer from the Watch List or Restricted List when the information is no longer material or non-public.
Specific Procedures Relating to the Safeguarding of Inside Information.
To ensure the integrity of the Information Barrier, and the confidentiality of the Restricted List, it is important that you take the following steps to safeguard the confidentiality of material, non- public information:
∙Do not discuss confidential information in public places such as elevators, hallways or social gatherings;
∙To the extent practical, limit access to the areas of the firm where confidential information could be observed or overheard to employees with a business need for being in the area;
∙Avoid using speaker phones in areas where unauthorized persons may overhear conversations;
∙Where appropriate, maintain the confidentiality of client identities by using code names or numbers for confidential projects;
∙Exercise care to avoid placing documents containing confidential information in areas where they may be read by unauthorized persons and store such documents in secure locations when they are not in use; and
∙Destroy copies of confidential documents no longer needed for a project. However, Record Retention and Destruction guidelines should be reviewed before taking any action.
ADDITIONAL PROCEDURES
Education Program. While the probability of research analysts and portfolio managers being exposed to material, non-public information with respect to issuers considered for investment by clients is greater than that of other personnel, it is imperative that all personnel understand this Statement, particularly since the insider trading restrictions also apply to transactions in the stock of Price Group.
To ensure that all appropriate personnel are properly informed of and understand Price Group's policy with respect to insider trading, the following program has been adopted.
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Initial Review and Training for New Personnel. All new persons subject to the Code, which includes this Statement, will be given the Code at the time of their association and will be required to certify that they have read it. In addition, each new employee is required to take web-based training promptly after his or her start date.
Revision of Statement. All persons subject to the Code will be informed whenever this Statement is materially revised.
Annual Review. All persons subject to the Code receive training on the Code annually.
Acknowledgement of Compliance. All persons subject to the Code will be asked to acknowledge their understanding of an adherence to the Code, including this Statement, on at least an annual basis.
Questions. If you have any questions with respect to the interpretation or application of this Statement, you are encouraged to discuss them with your immediate supervisor, the Legal Department, or the TRP International Compliance Team as appropriate.
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T. ROWE PRICE GROUP, INC.
STATEMENT OF POLICY
ON
SECURITIES TRANSACTIONS
BACKGROUND INFORMATION.
Legal Requirement. In accordance with the requirements of the Securities Exchange Act of 1934 (the "Exchange Act"), the Investment Company Act of 1940, the Investment Advisers Act of 1940, the Insider Trading and Securities Fraud Enforcement Act of 1988, and the various UK and other jurisdictions' laws and regulations, Price Group and the mutual funds ("Price Funds") which its affiliates manage, have adopted this Statement of Policy on Securities Transactions ("Statement").
Price Advisers' Fiduciary Position. As investment advisers, the Price Advisers are in a fiduciary position which requires them to act with an eye only to the benefit of their clients, avoiding those situations which might place, or appear to place, the interests of the Price Advisers or their officers, directors and employees in conflict with the interests of clients.
Purpose of Statement of Policy. The Statement was developed to help guide Price Group's employees and independent directors and the independent directors of the Price Funds in the conduct of their personal investments and to:
∙Eliminate the possibility of a transaction occurring that the SEC or other regulatory bodies would view as inconsistent with our role as a fiduciary;
∙Avoid situations where it might appear that Price Group or the Price Funds or any of their officers, directors, employees, or other personnel had personally benefited at the expense of a client or fund shareholder or taken inappropriate advantage of their fiduciary positions; and
∙Prevent, as well as detect, the misuse of material, non-public information.
Price Group's and the Price Funds' reputations could be adversely affected as the result of even a single transaction considered questionable in light of the fiduciary duties of the Price Advisers and the independent directors of the Price Funds.
QUESTIONS ABOUT THE STATEMENT. Questions regarding the policy can be directed to Code Compliance (Code_of_Ethics@TRowePrice.com).
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EXCESSIVE TRADING AND MARKET TIMING OF MUTUAL FUND SHARES. The issue of excessive trading and market timing by mutual fund shareholders is a serious one and is not unique to T. Rowe Price. Employees may not engage in trading of shares of a Price Fund that is inconsistent with the prospectus of that Fund.
Excessive or short-term trading in fund shares may disrupt management of a fund and raise its costs. The Board of Directors/Trustees of the Price Funds have adopted a policy to deter excessive and short-term trading (the "Policy"), which applies to persons trading directly with T. Rowe Price and indirectly through intermediaries. Under this Policy, T. Rowe Price may bar excessive and short-term traders from purchasing shares.
This Policy is set forth in each Fund's prospectus, which governs all trading activity in the Fund regardless of whether you are holding T. Rowe Price Fund shares as a retail investor or through your T. Rowe Price U.S. Retirement Program account.
Although the Fund may issue a warning letter regarding excessive trading or market timing, any trade activity in violation of the Policy will also be reviewed by the Chief Compliance Officer, who will refer instances to the Ethics Committee as he or she feels appropriate. The Ethics Committee, based on its review, may take disciplinary action, including suspension of trading privileges, forfeiture of profits or the amount of losses avoided, and termination of employment, as it deems appropriate.
Employees are also expected to abide by trading restrictions imposed by other funds as described in their prospectuses. If you violate the trading restrictions of a non-Price Fund, the Ethics Committee may impose the same penalties available for violation of the Price Funds excessive trading Policy.
FRONT RUNNING. Front Running is inconsistent with our responsibility to serve the interests of clients. It is generally defined as the purchase or sale of a security by an officer, director or employee of an investment adviser or mutual fund in anticipation of and prior to the adviser effecting similar transactions for its clients in order to take advantage of or avoid changes in market prices affected by client transactions.
PERSONS SUBJECT TO STATEMENT. The provisions of this Statement apply as described below to the following persons and entities. Each person and entity (except the independent directors of Price Group) is classified as either an Access Person or a Non-Access Person as described below. The provisions of this Statement may also apply to an Access Person's or Non- Access Person's spouse, minor children, and certain other relatives, as further described on page 5-4 of this Statement. All Access Persons except the independent directors of the Price Funds are subject to all provisions of this Statement except certain restrictions on purchases in initial public offerings that apply only to Investment Personnel. The independent directors of the Price Funds are not subject to prior transaction clearance requirements and are subject to modified reporting as described on page 5-19. Non-Access Persons are subject to the general principles of the Statement and its reporting requirements but are only required to receive prior transaction clearance for transactions in Price Group stock. The persons and entities covered by this Statement are:
Price Group. Price Group, each of its subsidiaries and affiliates, and their retirement plans.
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Employee Partnerships. Partnerships such as Pratt Street Ventures.
Personnel. Each officer, inside director and employee of Price Group and its subsidiaries and its affiliates.
Certain Contingent Workers. These workers include:
∙All contingent workers whose assignments exceed four weeks or whose cumulative assignments exceed eight weeks over a twelve-month period and whose work is closely related to the ongoing work of Price Group's employees (versus project work that stands apart from ongoing work); and
∙Any contingent worker whose assignment is more than casual in nature or who will be exposed to the kinds of information and situations that would create conflicts on matters covered in the Code.
Exceptions must be approved by Code Compliance (Code_of_Ethics@TRowePrice.com)
Independent Directors of Price Group and the Price Funds. The independent directors of Price Group include those directors of Price Group who are neither officers nor employees of Price Group or any of its subsidiaries or affiliates. The independent directors of the Price Funds include those directors of the Price Funds who are not deemed to be "interested persons" of Price Group.
Although subject to the general principles of this Statement, including the definition of "beneficial ownership," independent directors are subject only to modified reporting requirements (pages 5-19 to 5-22). The trades of the independent directors of the Price Funds are not subject to prior transaction clearance requirements. The trades of the independent directors of Price Group are not subject to prior transaction clearance requirements except for transactions in Price Group stock.
ACCESS PERSONS. Certain persons and entities are classified as "Access Persons" under the Code. The term "Access Persons" means:
∙The Price Advisers;
∙Any officer or director of any of the Price Advisers or the Price Funds (except the independent directors of the Price Funds);
∙Any person associated with any of the Price Advisers or the Price Funds who, in connection with his or her regular functions or duties, makes, participates in, obtains or has access to non-public information regarding the purchase or sale of securities by a Price Fund or other advisory client, or to non-public information regarding any securities holdings of any client of a Price Adviser, including the Price Funds, or whose functions relate to the making of any recommendations with respect to the purchases or sales.
All Access Persons are notified of their status under the Code.
Investment Personnel. An Access Person is further identified as "Investment Personnel" if, in connection with his or her regular functions or duties, he or she "makes or participates in making recommendations regarding the purchase or sale of securities" by a Price Fund or other advisory client.
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The term "Investment Personnel" includes, but is not limited to:
∙Those employees who are authorized to make investment decisions or to recommend securities transactions on behalf of the firm's clients (investment counselors and members of the mutual fund advisory committees);
∙Research and credit analysts; and
∙Traders who assist in the investment process.
All Investment Personnel are deemed Access Persons under the Code.
NON-ACCESS PERSONS. Persons who do not fall within the definition of Access Persons are deemed "Non-Access Persons." If a Non-Access Person is married to an Access Person, then the non-Access Person is deemed to be an Access Person.
TRANSACTIONS SUBJECT TO STATEMENT. Except as provided below, the provisions of this Statement apply to transactions that fall under either one of the following two conditions:
First, you are a "beneficial owner" of the security under the Rule 16a-1 of the Exchange Act, defined as follows; or
Second, if you control or direct securities trading for another person or entity, those trades are subject to this Statement even if you are not a beneficial owner of the securities. For example, if you have an exercisable trading authorization (e.g., a power of attorney to direct transactions in another person's account) of an unrelated person's or entity's brokerage account, or are directing another person's or entity's trades, those transactions will usually be subject to this Statement to the same extent your personal trades would be as described below.
Definition of Beneficial Owner. A "beneficial owner" is any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise, has or shares in the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the security. Being the beneficiary of an account, such as a 401(k) or securities account, does not necessarily mean a person is a "beneficial owner" unless one of the following conditions exists.
A person has beneficial ownership in:
∙Securities held by members of the person's immediate family (e.g. spouse, child, etc.) sharing the same household, although the presumption of beneficial ownership may be rebutted;
∙A person's interest in securities held by a trust, which may include both trustees with investment control and, in some instances, trust beneficiaries;
∙A person's right to acquire securities through the exercise or conversion of any derivative security, whether or not presently exercisable;
∙A general partner's proportionate interest in the portfolio securities held by either a general or limited partnership;
∙Certain performance-related fees other than an asset-based fee, received by any broker, dealer, bank, insurance company, investment company, investment adviser, investment manager, trustee or person or entity performing a similar function; and
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∙A person's right to dividends that are separated or separable from the underlying securities. Otherwise, right to dividends alone shall not represent beneficial ownership in the securities.
A shareholder shall not be deemed to have beneficial ownership in the portfolio securities held by a corporation or similar entity in which the person owns securities if the shareholder is not a controlling shareholder of the entity and does not have or share investment control over the entity's portfolio. If you become the beneficial owner of another's securities (e.g., by marriage to the owner of the securities) or begin to direct trading of another's securities, then the associated securities accounts become subject to the account reporting requirements outlined on page 5-16.
Requests for Clarifications or Interpretations Regarding Beneficial Ownership or Control. If you have beneficial ownership of a security, any transaction involving that security is presumed to be subject to the relevant requirements of this Statement, unless you have no direct or indirect influence or control over the transaction. Such a situation may arise, for example, if you have delegated investment authority to an independent investment adviser or your spouse has an independent trading program in which you have no input. Similarly, if your spouse has investment control over, but not beneficial ownership in, an unrelated account, the Statement may not apply to those securities and you may wish to seek clarification or an interpretation.
If you are involved in an investment account for a family situation, trust, partnership, corporation, etc., which you feel should not be subject to the Statement's relevant prior transaction clearance and/or reporting requirements, you should submit a written request for clarification or interpretation to either Code Compliance (Code_of_Ethics@TRowePrice.com) or the TRP International Compliance Team. Any such request for clarification or interpretations should name the account, your interest in the account, the persons or firms responsible for its management, and the specific facts of the situation. Do not assume that the Statement is not applicable; you must receive a clarification or interpretation about the applicability of the Statement. Clarifications and interpretations are not self-executing; you must receive a response to a request for clarification or interpretation directly from the Code Compliance Team or the TRP International Compliance Team before proceeding with the transaction or other action covered by this Statement.
PRIOR TRANSACTION CLEARANCE REQUIREMENTS GENERALLY. As described, certain transactions require prior clearance before execution. Receiving prior transaction clearance does not relieve you from conducting your personal securities transactions in full compliance with the Code, including its prohibition on trading while in possession of material, inside information, and the 60-Day Rule, and with applicable law, including the prohibition on Front Running.
TRANSACTIONS IN STOCK OF PRICE GROUP. Because Price Group is a public company, ownership of its stock subjects its officers, inside and independent directors, employees and all others subject to the Code to special legal requirements under the U.S. securities laws. You are responsible for your own compliance with these requirements. In connection with these legal requirements, Price Group has adopted the following rules and procedures:
Independent Directors of Price Funds. The independent directors of the Price Funds are prohibited from owning the stock or other securities of Price Group.
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Quarterly Earnings Report. Generally, all Access Persons and Non-Access Persons and the independent directors of Price Group must refrain from initiating transactions in Price Group stock in which they have a beneficial interest from the second trading day after quarter end (or such other date as management shall from time to time determine) through the day of filing the firm's earnings release with the SEC. You will be notified quarterly in regards to the controlling (blackout) dates.
Prior Transaction Clearance of Price Group Stock Transactions Generally. Access Persons and Non-Access Persons and the independent directors of Price Group are required to obtain clearance prior to effecting any proposed transaction (including gifts and transfers of beneficial ownership) involving shares of Price Group stock owned beneficially, including any Price Group stock owned in the Employee Stock Purchase Plan ("ESPP"). Moving shares of Price Group stock (held outside of the ESPP) between securities firms or to/from street name accounts with the same registration does not have to receive prior clearance but must be reported.
Prior Transaction Clearance Procedures for Price Group Stock. Requests for prior transaction clearance must be submitted to the myTRPcompliance system.
Gifts. The giving of or receipt of Price Group stock (TROW) must be prior cleared. This includes donation transactions into donor-advised funds such as T. Rowe Price Charitable, as well as any other charitable gifting.
Prohibition Regarding Transactions in Price Group Options. Transactions in options (other than stock options granted to T. Rowe Price associates) on Price Group stock are not permitted.
Prohibition Regarding Short Sales of Price Group Stock. Short sales of Price Group stock are not permitted.
Hedging Transactions in Price Group Stock. Entering into any contract or purchasing any instrument designed to hedge or offset any decrease in the market value of Price Group stock is not permitted.
Applicability of 60-Day Rule to Price Group Stock Transactions. Transactions in Price Group stock are subject to the 60-Day Rule except for transactions effected through the ESPP, the exercise of employee stock options granted by Price Group and the subsequent sale of the derivative shares, and shares obtained through an established dividend reinvestment program. Refer to page 5-25 for a full description of the 60-Day Rule.
Only Price Group stock that has been held for at least 60 days may be gifted. You must receive prior clearance before gifting shares of Price Group stock. Purchases of Price Group stock in the ESPP through payroll deduction are not considered in determining the applicability of the 60-Day Rule to market transactions in Price Group stock. To avoid issues with the 60-day rule, shares may not be transferred out of or otherwise removed from the ESPP if the shares have been held for less than 60 days.
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Access Persons and Non-Access Persons and the independent directors of Price Group must obtain prior transaction clearance of any transaction involving Price Group stock, (unless specifically exempted, such as transfers of form of ownership).
Initial Disclosure of Holdings of Price Group Stock. Each new employee must report any shares of Price Group stock of which he or she has beneficial ownership no later than ten business days after his or her starting date.
Dividend Reinvestment Plans for Price Group Stock. Purchases of Price Group stock owned outside of the ESPP and effected through a dividend reinvestment plan need not receive prior transaction clearance. Reporting of transactions effected through that plan need only be made quarterly through statements provided to the Code Compliance Team or by the financial institution (e.g. broker-dealer) where the account is maintained, except in the case of employees who are subject to Section 16 of the Exchange Act, who must report such transactions immediately.
Effectiveness of Prior Clearance. Prior transaction clearance of transactions in Price Group stock is effective for three U.S. business days from and including the date the clearance is granted, unless (i) advised to the contrary by the Payroll and Stock Transaction Group prior to the proposed transaction, or (ii) the person receiving the clearance comes into possession of material, non-public information concerning the firm. If the proposed transaction in Price Group stock is not executed within this time period, a new clearance must be obtained before the individual can execute the proposed transaction.
Reporting of Disposition of Proposed Transaction. If the transaction request was executed, the Payroll & Stock Transaction Team will receive an electronic or paper confirmation of the transaction and your records will be updated accordingly.
Insider Reporting and Liability. Under current SEC rules, certain officers, directors and 10% stockholders of a publicly traded company ("Insiders") are subject to the requirements of Section 16. Insiders include the directors and certain executive officers of Price Group. The Payroll and Stock Transaction Group informs all those who are Insiders of their obligations under Section 16.
SEC Reporting. There are three reporting forms which Insiders are required to file with the SEC to report their purchase, sale and transfer transactions in, and holdings of, Price Group stock. Although the Payroll and Stock Transaction Group will provide assistance in complying with these requirements as an accommodation to Insiders, it remains the legal responsibility of each Insider to ensure that the applicable reports are filed in a timely manner.
∙Form 3. The initial ownership report by an Insider is required to be filed on Form 3. This report must be filed within ten days after a person becomes an Insider (i.e., is elected as a director or appointed as an executive officer) to report all current holdings of Price Group stock. Following the election or appointment of an Insider, the Payroll and Stock Transaction Group will deliver to the Insider a Form 3 for appropriate signatures and will file the form electronically with the SEC.
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∙Form 4. Any change in the Insider's ownership of Price Group stock must be reported on a Form 4 unless eligible for deferred reporting on year-end Form 5. The Form 4 must be filed electronically before the end of the second business day following the day on which a transaction resulting in a change in beneficial ownership has been executed. Following receipt of the Notice of Disposition of the proposed transaction, the Payroll and Stock Transaction Group will deliver to the Insider a Form 4, as applicable, for appropriate signatures and will file the form electronically with the SEC.
∙Form 5. Any transaction or holding that is exempt from reporting on Form 4, such as small purchases of stock, gifts, etc. may be reported electronically on a deferred basis on Form 5 within 45 calendar days after the end of the calendar year in which the transaction occurred. No Form 5 is necessary if all transactions and holdings were previously reported on Form 4.
Liability for Short-Swing Profits. Under the U.S. securities laws, profit realized by certain officers, as well as directors and 10% stockholders of a company (including Price Group) as a result of a purchase and sale (or sale and purchase) of stock of the company within a period of less than six months must be returned to the firm or its designated payee upon request.
PRIOR TRANSACTION CLEARANCE REQUIREMENTS - ACCESS PERSONS.
Access Persons must obtain prior transaction clearance before directly or indirectly initiating, recommending, or in any way participating in, the purchase or sale of a security in which the Access Person has, or by reason of such transaction may acquire, any beneficial interest or which the Access Person controls. This includes the writing of an option to purchase or sell a security and the acquisition of any shares in an Automatic Investment Plan through a non-systematic investment. Following are exceptions to the prior transaction clearance requirement:
∙The independent directors of the Price Funds are generally not required to receive prior transaction clearance so long as they have no knowledge of trades being transacted for the Price Funds; and
∙Any Price Adviser is not required to receive prior transaction clearance when T. Rowe Price seed money is deployed to establish a client/product strategy.
Non-Access Persons are not required to obtain prior clearance before engaging in any securities transactions, except for transactions in Price Group stock.
Where required, prior transaction clearance must be obtained regardless of whether the transaction is affected through TRP Brokerage (generally available only to U.S. residents) or through an unaffiliated broker-dealer or other entity. Please note that the prior clearance procedures do not check compliance with the 60-Day Rule (page 5-25); you are responsible for ensuring your compliance with this rule.
TRANSACTIONS (OTHER THAN IN PRICE GROUP STOCK) THAT DO NOT REQUIRE EITHER PRIOR TRANSACTION CLEARANCE OR REPORTING UNLESS THEY OCCUR IN A "REPORTABLE FUND." The following transactions
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do not require either prior transaction clearance or reporting:
Mutual Funds and Variable Insurance Products. The purchase or redemption of shares of any open-end investment companies and variable insurance products, except that Access Persons must report transactions in Reportable Funds (page 5- 11).
Undertakings for Collective Investments in Transferrable Securities (UCITS). The purchase or redemption of shares in an open-ended European investment fund established in accordance with the UCITS Directive provided that a Price Adviser does not serve as an adviser to the fund.
Automatic Investment Plans. Transactions through a program in which regular periodic purchases or withdrawals are made automatically in or from investment accounts in accordance with a predetermined schedule and allocation. However, the initial automatic investment does require prior clearance. An Access Person must report any securities owned as a result of transactions in an Automatic Investment Plan on his or her Annual Report. Any transaction that overrides the pre-set schedule or allocations of an automatic investment plan (a "non-systematic transaction") must be reported by both Access Persons and non-Access Persons and Access Persons must also receive prior transaction clearance for such a transaction if the transaction would otherwise require prior transaction clearance.
Donor-Advised Funds. Transactions within donor-advised funds, such as
T. Rowe Price Charitable, do not require prior clearance or reporting. However, a gift of Price Group stock into a donor-advised fund is required to be prior cleared and reported.
U.S Government Obligations. Purchases or sales of direct obligations of the U.S Government.
Certain Commodity Futures Contracts. Purchases or sales of commodity futures contracts for tangible goods (e.g., corn, soybeans, wheat) if the transaction is regulated solely by the U.S. Commodity Futures Trading Commission ("CFTC"). Commodity futures contracts for financial instruments such as ETFs, however, must be reported.
Commercial Paper and Similar Instruments. Bankers' acceptances, bank certificates of deposit, commercial paper and high-quality, short-term debt instruments, including repurchase agreements.
Certain Unit Investment Trusts. Shares issued by unit investment trusts that are invested exclusively in one or more open-end funds, if none of the underlying funds is a Reportable Fund.
Currency. Direct foreign currency transactions (spot and forward trades) in the Japanese Yen or British Pound, for example. However, securitized or financial instruments used for currency exposure (e.g. ProShares Ultra Yen ETF), must be reported.
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Cryptocurrency. Transactions in cryptocurrency, such as Bitcoin, Ethereum, etc., do not require prior clearance or reporting. However, transactions in any publicly- traded cryptocurrency tracker instrument would require prior clearance and reporting. Participation in Initial Coin Offerings (ICOs) is prohibited.
TRANSACTIONS (OTHER THAN PRICE GROUP STOCK) THAT DO NOT REQUIRE PRIOR TRANSACTION CLEARANCE BUT MUST BE REPORTED BY BOTH ACCESS PERSONS AND NON-ACCESS PERSONS. The following transactions do not require prior transaction clearance but must be reported:
Exchange-Traded Funds ("ETFs"). Transactions in ETFs, including ETFs authorized as UCITS, do not require prior clearance but must be reported. However, transactions in narrow, inverse (also known as short or inverse leveraged) ETFs are prohibited. Short sale transactions in narrow, long ETFs are also prohibited. Access Persons are responsible for their compliance to these two prohibitions. Contact the Code Compliance Team regarding any uncertainty in contemplated ETF transactions. Narrow ETFs include, but are not limited to, those focused on specific industries (e.g. energy, healthcare, financial services, etc.), commodities, currencies, and specific geographical markets (e.g. countries or regions).
Unit Investment Trusts. Purchases or sales of shares in unit investment trusts registered under the Investment Company Act of 1940, unless the unit investment trust is an ETF, in which case the ETF protocols apply.
National Government Obligations (other than U.S.). Purchases or sales of direct obligations of national (non-U.S.) governments.
Variable Rate Demand Notes. This financial instrument is an unsecured debt obligation of a corporate entity. These instruments generally pay a floating interest rate slightly above the prevailing money market rates and include check-writing capabilities. It is not a money market fund nor is it equivalent to a bank deposit or bank account, therefore the instrument is not protected by the Securities Investor Protection Corporation or Federal Deposit Insurance Corporation.
Pro Rata Distributions. Purchases effected by the exercise of rights issued pro-rata to all holders of a class of securities or the sale of rights so received.
Tender Offers. Purchases and sales of securities pursuant to a mandatory (e.g., the holder has no choice or elections regarding the offer) tender offer. Merger elections, however, that presents holders of acquired securities, with exchange options that typically include cash or securities of the acquiring company and/or a combination thereof, must be prior cleared.
Exercise of Stock Option of Corporate Employer by Spouse. Transactions involving the exercise by an Access Person's spouse of a stock option issued by the corporation employing the spouse. However, a subsequent sale of the stock obtained by means of the
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exercise, including sales effected by a "cash-less" transactions, must receive prior transaction clearance.
Restricted Stock Plan Automatic Sales for Tax Purposes by Spouse. Transactions commonly called "net sales" whereby upon vesting of restricted shares, a portion of the shares are automatically sold in order to cover the tax obligation.
Inheritances. The acquisition of securities through inheritance.
Gifts. The giving of or receipt of a security as a gift. However, a gift of or receipt of Price Group stock must be prior cleared.
Stock Splits, Reverse Stock Splits, and Similar Acquisitions and Dispositions. The mandatory acquisition of additional shares or the disposition of existing corporate holdings through stock splits, reverse stock splits, stock dividends, exercise of rights, exchange or conversion. Reporting of such transactions must be made within 30 days of the end of the quarter in which they occurred. Reporting is deemed to have been made if the acquisition or disposition is reported on a confirmation, statement or similar document sent to Code Compliance.
Spousal Employee-Sponsored Payroll Deduction Plans. Purchases, but not sales, by an Access Person's spouse pursuant to an employee-sponsored payroll deduction plan (e.g., a 401(k) plan or employee stock purchase plan), provided the Code Compliance Section has been previously notified by the Access Person that the spouse will be participating in the payroll deduction plan. Reporting of such transactions must be made within 30 days of the end of the quarter in which they occurred. A sale or exchange of stock held in such a plan is subject to the prior transaction clearance requirements for Access Persons.
Partial Shares Sold. Partial shares held in an account that are sold when the account is transferred to another broker-dealer or to new owner or partial shares sold automatically by the broker-dealer.
TRANSACTIONS (OTHER THAN PRICE GROUP STOCK) THAT DO NOT REQUIRE PRIOR TRANSACTION CLEARANCE BUT MUST BE REPORTED BY ACCESS PERSONS ONLY.
Reportable TRP-Advised Funds ("Reportable Funds") Not Held On A T. Rowe Price Platform. Access Persons must report the purchases and sales of shares of Reportable Funds. A Reportable Fund is any open-end investment company, including money market funds and UCITS, for which any of the Price Advisers serves as an investment adviser. This includes not only the Price Funds, SICAVs, OEICs, and any Price-advised investment products, but also any fund managed by any of the Price Advisers either through subadvised relationships, including any fund holdings offered through retirement plans (e.g., 401(k) plans) other than the T. Rowe Price U.S. Retirement Plan, or as an investment option offered as part of a variable annuity. Code Compliance maintains a listing of subadvised Reportable Funds on the TRP Exchange.
Access Persons must inform the Code Compliance Team about ownership of shares of Price Funds. Once this notification has been given, if the Price Fund is held on a T. Rowe
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Price platform, in a TRP Brokerage Account, or in the T. Rowe Price U.S. Retirement Plan, the Access Person need not report these transactions directly. In instances where Price Funds are held through an intermediary, transactions in shares of those Price Funds must be reported as described on page 5-18.
Interests in Section 529 College Savings Plans not held on the T. Rowe Price Platform. Access Persons must report the purchase and sale of interests in any Section 529 College Savings Plan for which any Price Adviser serves as an adviser or subadviser to the plan. Access Persons must inform the Code Compliance Team about ownership of interests in the Maryland College Investment Plan, the T. Rowe Price College Savings Plan and the University of Alaska College Savings Plan. For these specific plans only, once this notification has been given, an Access Person need not report transactions directly (page 5-18). In instances where ownership interests in 529 College Savings Plans that are advised or subadvised by a Price Adviser are held through an intermediary, transactions must be reported as described on page 5-18.
The Chief Compliance Officer or his or her designee reviews at a minimum the transaction reports for all securities required to be reported under the Advisers Act or the Investment Company Act for all employees, officers, and inside directors of Price Group and its affiliates and for the independent directors of the Price Funds.
TRANSACTIONS THAT REQUIRE PRIOR TRANSACTION CLEARANCE BY ACCESS PERSONS. If the transaction or security is not subject to prior transaction clearance, as outlined in this policy, you should assume that it is subject to the prior clearance requirement unless specifically informed otherwise by the Code Compliance Team or the TRP International Compliance Team.
Among the transactions for which Access Persons must receive prior transaction clearance are:
∙Non-systematic transactions in a security that is not exempt from prior transaction clearance;
∙Close-end fund transactions, including U.K, Canadian, and other non-U.S. investment trusts.
OTHER TRANSACTION REPORTING REQUIREMENTS. Any transaction that is subject to the prior transaction clearance requirements on behalf of an Access Person (except the independent directors of the Price Funds), including purchases in initial public offerings and private placement transactions, must be reported. Although Non-Access Persons are not required to receive prior transaction clearance for securities transactions (other than Price Group stock), they must report any transaction that would require prior transaction clearance by an Access Person. The independent directors of Price Group and the Price Funds are subject to modified reporting requirements.
PROCEDURES FOR OBTAINING PRIOR TRANSACTION CLEARANCE (OTHER THAN PRICE GROUP STOCK) FOR ACCESS PERSONS. Unless prior transaction clearance is not required as described in this policy or determined by the Chairperson of the Ethics Committee, Access Persons must receive prior transaction clearance for all securities transactions.
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Access Persons should follow the procedures before engaging in the transactions described. If an Access Person is not certain whether a proposed transaction is subject to the prior transaction clearance requirements, he or she should contact the Code Compliance Team before proceeding.
Procedures for Obtaining Prior Transaction Clearance for Initial Public Offerings ("IPOs"):
Non-Investment Personnel. Access Persons who are not Investment Personnel ("Non- Investment Personnel") may purchase securities that are the subject of an IPO only after receiving prior transaction clearance in writing from the Chairperson of the Ethics Committee or their designee. An IPO would include, for example, an offering of securities registered under the Securities Act of 1933 when the issuer of the securities, immediately before the registration, was not subject to certain reporting requirements of the Exchange Act. This requirement applies to all IPOs regardless of market.
In considering such a request for prior transaction clearance, the Chairperson or their designee will determine whether the proposed transaction presents a conflict of interest with any of the firm's clients or otherwise violates the Code. The Chairperson or his or her designee will also consider whether:
1.The purchase is made through the Non-Investment Personnel's regular broker;
2.The number of shares to be purchased is commensurate with the normal size and activity of the Non-Investment Personnel's account; and
3.The transaction otherwise meets the requirements of the FINRA restrictions, as applicable, regarding the sale of a new issue to an account in which a
"restricted person," as defined in FINRA Rule 5130, has a beneficial interest.
Non-Investment Personnel will not be permitted to purchase shares in an IPO if any of the firm's clients are prohibited from doing so because of affiliated transaction restrictions. This prohibition will remain in effect until the firm's clients have had the opportunity to purchase in the secondary market once the underwriting is completed commonly referred to as the aftermarket. The 60-Day Rule applies to transactions in securities purchased in an IPO.
Investment Personnel. Investment Personnel may not purchase securities in an IPO.
Non-Access Persons. Although Non-Access Persons are not required to receive prior transaction clearance before purchasing shares in an IPO, any Non-Access Person who is a registered representative or associated person of Investment Services is reminded that FINRA Rule 5130 may restrict his or her ability to buy shares in a new issue in any market.
Procedures for Obtaining Prior Transaction Clearance for Private Placements:
Access Persons may not invest in a private placement of securities, including the purchase of limited partnership interests, unless prior transaction clearance in writing has been obtained from the Chairperson of the Ethics Committee or their designee. This prior clearance provision includes situations involving investment transactions made in small businesses typically sourced through family or friends as well as any other referral source.
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A private placement is generally defined as an offering that is exempt from registration by a regulatory authority and sold through a private offering. Private placement investments generally require the investor to complete a written questionnaire or subscription agreement and be regarded as a professional or accredited investor.
Crowdfunding. Investments made through crowdfunding sites that serve to match entrepreneurs with investors, through which investors receive an equity stake in the business, are generally considered to be private placements and would require prior clearance. In contrast, providing funding through crowdfunding sites that serve to fund projects or philanthropic ventures are not considered private placements and therefore would not require prior clearance.
If an Access Person has any questions about whether a transaction is, in fact, a private placement, he or she should contact the Chairperson of the Ethics Committee or their designee.
In considering a request for prior transaction clearance for a private placement, the Chairperson will determine whether the investment opportunity (private placement) should be reserved for the firm's clients, and whether the opportunity is being offered to the Access Person by virtue of his or her position with the firm. The Chairperson will also secure, if appropriate, the approval of the proposed transaction from the chairperson of the applicable investment steering committee.
Continuing Obligation. An Access Person who has received prior transaction clearance to invest and does invest in a private placement of securities and who, at a later date, anticipates participating in the firm's investment decision process regarding the purchase or sale of securities of the issuer of that private placement on behalf of any client, must immediately disclose his or her prior investment in the private placement to the Chairperson of the Ethics Committee and to the chairperson of the appropriate investment steering committee.
Registered representatives of Investment Services are reminded that FINRA rules may restrict investment in a private placement in certain circumstances.
Procedures for Obtaining Prior Transaction Clearance for All Other Securities Transactions:
Requests for prior transaction clearance by Access Persons for all other securities transactions requiring prior transaction clearance should generally be made via myTRPcompliance on the firm's intranet. The myTRPcompliance system automatically sends any request for prior transaction approval that requires manual intervention to the Code Compliance Team. If you cannot access myTRPcompliance, requests may be made by email to the Legal Compliance Employee Trading mailbox. All requests must include the name of the security, a definitive security identifier (e.g., CUSIP, ticker, or Sedol), the number of shares or amount of bond involved, and the nature of the transaction, i.e., whether the transaction is a purchase, sale, short sale, or buy to cover. Responses to all requests will be made by myTRPcompliance or the Code Compliance Team, documenting the request and whether or not prior transaction clearance has been granted. The
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myTRPcompliance system maintains the record of all approval and denials, whether automatic or manual.
Effectiveness of Prior Transaction Clearance. Prior transaction clearance of a securities transaction is effective for three U.S. business days from and including the date the clearance is granted, regardless of the time of day when clearance is granted. If the proposed securities transaction is not executed within this time, a new clearance must be obtained. For example, if prior transaction clearance is granted at 2:00 pm Monday, the trade must be executed by Wednesday. In situations where it appears that the trade will not be executed within three business days even if the order is entered in that time period (e.g., certain transactions through transfer agents or spousal employee-sponsored payroll deduction plans), please notify the Code Compliance Team after prior clearance has been granted, but before entering the order with the executing agent.
Reminder. If you are an Access Person and become the beneficial owner of another's securities (e.g., by marriage to the owner of the securities) or begin to direct trading of another's securities, then transactions in those securities also become subject to the prior transaction clearance requirements. You must also report acquisition of beneficial ownership or control of these securities within ten business days of your knowledge of their existence.
REASONS FOR DISALLOWING ANY REQUESTED TRANSACTION. Prior transaction clearance will usually not be granted if:
Pending Client Orders. Orders have been placed by any of the Price Advisers to purchase or sell the security unless certain size or volume parameters as described (on page 5-23) under "Large Issuer/Volume Transactions" are met.
Purchases and Sales within Seven Calendar Days. The security has been purchased or sold by any client of a Price Adviser within seven calendar days immediately prior to the date of the proposed transaction, unless certain size or volume parameters as described (on page 5-23) under "Large Issuer/Volume Transactions" are met.
For example, if a client transaction occurs on Monday, prior transaction clearance is not generally granted to An Access Person to purchase or sell that security until Tuesday of the following week. Transactions in securities in pure, as opposed to enhanced, index funds are not considered for this purpose. If all clients have eliminated their holdings in a particular security, the seven-calendar day restriction is not applicable to an Access Person's transactions in that security.
Company Rating Changes. A change in the rating of a company has occurred within seven calendar days immediately prior to the date of the proposed transaction. Accordingly, trading would not be permitted until the eighth calendar day.
Securities Subject to Internal Trading Restrictions. The security is limited or restricted by any of the Price Advisers as to purchase or sale by Access Persons.
Requests for Reconsideration of Prior Transaction Clearance Denials. If an Access Person has not been granted a requested prior transaction clearance, he or she may apply to the Chairperson of the Ethics Committee or their designee for reconsideration. Such a request must
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be in writing and must fully describe the basis upon which the reconsideration is being requested. As part of the reconsideration process, the Chairperson or their designee will determine if any client of any of the Price Advisers may be disadvantaged by the proposed transaction by the Access Person. The factors the Chairperson or their designee may consider in making this determination include:
∙The size of the proposed transaction;
∙The nature of the proposed transaction (i.e., buy or sell) and of any recent, current or pending client transactions;
∙The trading volume of the security that is the subject of the proposed Access Person transaction;
∙The existence of any current or pending order in the security for any client of a Price Adviser;
∙The reason the Access Person wants to trade (e.g., to provide funds for the purchase of a home); and
∙The number of times the Access Person has requested prior transaction clearance for the proposed trade and the amount of time elapsed between each prior transaction clearance request.
TRANSACTION CONFIRMATIONS AND PERIODIC ACCOUNT STATEMENTS. All Access Persons (except the independent directors of the Price Funds) and Non-Access Persons must request broker-dealers, investment advisers, banks, or other financial institutions executing their transactions to send a duplicate confirmation or contract note with respect to each and every reportable transaction, including Price Group stock, and a copy of all periodic statements for all securities accounts in which the Access Person or Non-Access Person is considered to have beneficial ownership and/or control (see discussion of beneficial ownership and control concepts on page 5-4) to Code Compliance, Legal Department, T. Rowe Price, P.O. Box 17218, Baltimore, Maryland 21297-1218. T. Rowe Price has established relationships and electronic data feeds with many broker-dealers for purposes of obtaining duplicate confirmations and contract notes as well as periodic statements. Certain broker-dealers require employee consent before sending such confirmations, contract notes, and statements to T. Rowe Price. In those cases, Code Compliance will contact the employee and obtain the required authorization.
The independent directors of Price Group and the Price Funds are subject to modified reporting requirements described at pages 5-19 to 5-22.
If transaction or statement information is provided in a language other than English, the employee should provide an English translation.
NOTIFICATION OF SECURITIES ACCOUNTS. All persons and all entities subject to this Statement must report their securities accounts upon joining the firm as well as obtain prior approval for all new accounts opened while employed by T. Rowe Price. New T. Rowe Price brokerage accounts do not require prior approval but must be reported. Prior approval is obtained through myTRPcompliance and an instruction for obtaining such approval is located on the myTRPcompliance home page.
The independent directors of Price Group and the Price Funds are not subject to this requirement.
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New Personnel Subject to the Code. A person subject to the Code must give written notice of any existing securities accounts maintained with any broker, dealer, investment adviser, bank or other financial institution within ten business days of association with the firm.
Associates do not have to report accounts at transfer agents or similar entities if the only securities in those accounts are variable insurance products or open-end mutual funds if these are the only types of securities that can be held or traded in the accounts. If other securities can be held or traded, the accounts must be reported. For example, if you have an account at a transfer agent that can only hold shares of a mutual fund; that account does not have to be reported. If, however, you have a brokerage account it must be reported even if the only securities currently held or traded in it are mutual funds.
Officers, Directors and Registered Representatives of TRP Investment Services. FINRA requires each associated person of T. Rowe Price Investment Services to:
∙Obtain prior approval for a new securities account; and
∙If the securities account is with a broker-dealer, provide the broker-dealer with written notice of his or her association with TRP Investment Services.
Annual Statement by Access Persons. Every January each Access Person, except an Access Person who is an independent director of the Price Funds, must file with the firm a list of their accounts as of year-end.
PROCEDURES FOR REPORTING TRANSACTIONS. The following requirements apply both to Access Persons and Non-Access Persons except the independent directors of Price Group and the Price Funds, who are subject to modified reporting requirements:
Report Form. If the executing firm provides a confirmation, contract note or similar document directly to the firm, you do not need to make a further report. The date this document is received by the Code Compliance Team will be deemed the date the report is submitted for purposes of SEC compliance. The Code Compliance Team must receive the confirmation or similar document no later than 30 days after the end of the calendar quarter in which the transaction occurred. You must report all other transactions using the "Securities Transaction Report" form which is available in the myTRPcompliance system.
What Information Is Required. Each transaction report must contain, at a minimum, the following information about each transaction involving a reportable security in which you had, or as a result of the transaction acquired, any direct or indirect beneficial ownership:
∙The date of the transaction
∙The title of the security
∙The ticker symbol or CUSIP number, as applicable
∙The interest rate and maturity date, as applicable
∙The number of shares, as applicable
∙The principal amount of each reportable security involved, as applicable
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∙The nature of the transaction (i.e. purchase, sale or any other type of acquisition or disposition)
∙The price of the security at which the transaction was affected
∙The name of the broker, dealer or bank with or through which the transaction was affected; and
∙The date you submit the report
When Reports are Due. You must report a securities transaction within ten business days after the trade date or within ten business days after the date on which you first gain knowledge of the transaction (for example, a bequest) if this is later. A transaction in a Reportable Fund, a spousal payroll deduction plan or a stock split or similar acquisition or disposition must be reported within 30 days of the end of the quarter in which it occurred.
Access Person Reporting of Reportable Funds and T. Rowe Price-Advised Section 529 College Savings Plan Interests HELD on the T. Rowe Price Platform or HELD by the TRP UK Retirement Plan. You are required to inform Code Compliance about Reportable Funds and/or T. Rowe Price-advised Section 529 College Savings Plan interests (i.e., the Maryland College Investment Plan, the T. Rowe Price College Savings Plan and the University of Alaska College Savings Plan) held on the T. Rowe Price Platform or held by the TRP UK Retirement Plan. Once you have done this, you do not have to report any transactions in those securities. Your transactions and holdings will be updated and reported automatically to Code Compliance on a periodic basis. You should report your new account via myTRPcompliance (located on the Exchange) when you first establish an account in a Reportable Fund or invest in a T. Rowe Price-advised Section 529 College Savings Plan held on a T. Rowe Price Platform or held by the TRP UK Retirement Plan.
Access Person Reporting of Reportable Funds and T. Rowe Price-Advised Section 529 College Savings Plan Interests NOT HELD on the T. Rowe Price Platform. You must notify Code Compliance of any Reportable Fund or T. Rowe Price-advised Section 529 College Savings Plan interests that you beneficially own or control that are held at any intermediary. This would include, for example, a Price Fund held in your spouse's retirement plan, even if T. Rowe Price Retirement Plan Services acts as the administrator or record-keeper of that plan. Any transaction in a Reportable Fund or in interests in a T. Rowe Price-advised Section 529 College Savings Plan must be reported by duplicate transaction confirmations and statements sent directly by the intermediary to the Code Compliance Team or by the Access Person directly using the "Securities Transactions" form (located in myTRPcompliance) within 30 days of the end of the quarter in which the transaction occurred.
Reporting Certain Private Placement Transactions. If your investment requires periodic capital calls (e.g., in a limited partnership) you must report each capital call. This is required even if you are an Access Person and you received prior transaction clearance for a total cumulative investment. In addition, you must report any distributions you receive in the form of securities.
Reminder. If you become the beneficial owner of another's securities (e.g., by marriage to the owner of the securities) or begin to direct trading of another's securities, the transactions in these securities become subject to the transaction reporting requirements.
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REPORTING REQUIREMENTS FOR THE INDEPENDENT DIRECTORS OF THE PRICE FUNDS.
Transactions in Publicly Traded Securities. An independent director of the Price Funds must report transactions in publicly-traded securities where the independent director controls or directs such transactions. These reporting requirements apply to transactions the independent director effects for his or her own beneficial ownership as well as the beneficial ownership of others, such as a spouse or other family member. An independent director does not have to report securities transactions in accounts over which the independent director has no direct or indirect influence such as an account over which the independent director has granted full investment discretion to a financial adviser. The independent director should contact the Legal Department to request approval to exempt any such accounts from this reporting requirement.
Transactions in Non-Publicly Traded Securities. An independent director does not have to report transactions in securities which are not traded on an exchange (i.e., non-publicly traded securities), unless the independent director knew, or in the ordinary course of fulfilling his or her official duties as a Price Funds independent director, should have known that during the 15-day period immediately before or after the independent director's transaction in such non-publicly traded security, a Price Adviser purchased, sold or considered purchasing or selling such security for a Price Fund or Price advisory client.
Methods of Reporting. An independent director has the option to satisfy his or her obligation to report transactions in securities via a Quarterly Report or by arranging for the executing brokers of such transactions to provide duplicate transaction confirmations directly to the Code Compliance Team.
Quarterly Reports. If a Price Fund independent director elects to report his or her transactions quarterly: (1) a report for each securities transaction must be filed with the Code Compliance Team no later than thirty days after the end of the calendar quarter in which the transaction was effected; and
(2)a report must be filed for each quarter, regardless of whether there have been any reportable transactions. The Code Compliance Team will send to each independent director of the Price Funds who chooses to report transactions on a quarterly basis a reminder letter and reporting form approximately ten days before the end of each calendar quarter.
Duplicate Confirmation Reporting. An independent director of the Price Funds may also instruct his or her broker to send duplicate transaction confirmations directly to the Code Compliance Team. An independent director who chooses to have his or her broker send duplicate account information to the Code Compliance Team in lieu of directly reporting broker-executed transactions must nevertheless provide Quarterly Reports for any securities transactions for which a broker confirmation is not generated.
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Among the types of transactions that are commonly not reported through a broker confirmation and may therefore have to be reported directly to T. Rowe Price are:
∙Exercise of Stock Options of a Corporate Employer;
∙Inheritance of a Security;
∙Gift of a Security; and
∙Transactions in Certain Commodities Futures Contracts (e.g., financial indices).
An independent director of the Price Funds must include any transactions listed above, as applicable, in his or her Quarterly Reports if not otherwise contained in a duplicate broker confirmation. The Code Compliance Team will send to each independent director of the Price Funds who chooses to report transactions through broker confirmations a reminder letter approximately ten days before the end of each calendar quarter so that transactions not reported by broker confirmations can be reported.
Reporting of Officership, Directorship, General Partnership or Other Managerial Positions Apart from the Price Funds. An independent director of the Price Funds shall report to the Code Compliance Team any officership, directorship, general partnership, or other managerial position which he or she holds with any public, private, or governmental issuer other than the Price Funds.
Reporting of Significant Ownership.
Issuers (Other than Non-Public Investment partnerships, Pools or Funds). If an independent director of the Price Funds owns more than ½ of 1% of the total outstanding shares of a public or private issuer (other than a non-public investment partnership, pool or fund), he or she must immediately report this ownership in writing to the Code Compliance Team, providing the name of the issuer and the total number of the issuer's shares beneficially owned.
Non-Public Investment Partnerships, Pools or Funds. If an independent director of the Price Funds owns more than ½ of 1% of the total outstanding shares or units of a non-public investment partnership, pool or fund over which the independent director exercises control or influence, the independent director must report such ownership in writing to the Code Compliance Team. For non-public investment partnerships, pools or funds where the independent director does not exercise control or influence, the independent director need not report such ownership to the Code Compliance Section unless and until such ownership exceeds 4% of the total outstanding shares or units of the entity.
Investments in Price Group. An independent director of the Price Funds is prohibited from owning the common stock or other securities of Price Group.
Investments in Non-Listed Securities Firms. An independent director of the Price Funds may not purchase or sell the shares of a broker-dealer, underwriter or federally registered
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investment adviser unless that entity is traded on an exchange or the purchase or sale has otherwise been approved by the Price Fund Boards.
Dealing with Clients. Aside from market transactions effected through securities exchanges, an independent director of the Price Funds may not knowingly transact with a Price Fund. This prohibition does not preclude the purchase or redemption of shares of any open-end mutual fund that is a client of any Price Advisers.
Prior Transaction Clearance Requirements. The independent directors of the Price Funds are generally not required to receive prior transaction clearance so long as they have no knowledge of trades being transacted for the Price Funds.
REPORTING REQUIREMENTS FOR THE INDEPENDENT DIRECTORS OF PRICE GROUP OR ITS SUBSIDIARIES.
Reporting of Personal Securities Transactions. An independent director is not required to report his or her personal securities transactions (other than transactions in Price Group stock) as long as the independent director does not obtain information about the Price Advisers' investment research, recommendations, or transactions. However, each independent director is reminded that changes to certain information reported by the respective independent director in the Annual Questionnaire for Independent Directors are required to be reported to Corporate Records (e.g., changes in holdings of stock of financial institutions or financial institution holding companies).
Reporting of Officership, Directorship, General Partnership or Other Managerial Positions Apart from Price Group. An independent director shall report to the Code Compliance Team any officership, directorship, general partnership or other managerial position which he or she holds with any public, private, or governmental issuer other than Price Group or any of its subsidiaries.
Reporting of Significant Ownership.
Issuers (Other than Non-Public Investment Partnerships, Pools or Funds). If an independent director owns more than ½ of 1% of the total outstanding shares of a public or private issuer (other than a non-public investment partnership, pool or fund), he or she must report this ownership in writing to the Code Compliance Team, providing the name of the issuer and the total number of the issuer's shares beneficially owned.
Non-Public Investment Partnerships, Pools or Funds. If an independent director owns more than ½ of 1% of the total outstanding shares or units of a non-public investment partnership, pool or fund over which the independent director exercises control or influence, the independent director must report such ownership in writing to the Code Compliance Team. For non-public investment partnerships, pools or funds where the independent director does not exercise control or influence, the independent director need not report such ownership to the Code Compliance Team unless and until such ownership exceeds 4% of the total outstanding shares or units of the entity.
Investments in Non-Listed Securities Firms. An independent director should be mindful of potential conflicts of interest associated with transactions and/or ownership of a broker-dealer,
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underwriter or federally registered investment adviser that is not publicly traded. Directors should consult with the T. Rowe Price Chief Legal Counsel regarding such matters.
MISCELLANEOUSRULESREGARDINGPERSONAL SECURITIESTRANSACTIONS. These rules vary in their applicability depending upon whether you are an Access Person.
The following rules apply to all Access Persons, except the independent directors of the Price Funds, and to all Non-Access Persons:
Dealing with Clients. Access Persons and Non-Access Persons may not, directly or indirectly, sell to or purchase from a client any security. Market transactions are not subject to this restriction. This prohibition does not preclude the purchase or redemption of shares of any open-end mutual fund that is a client of any of the Price Advisers and does not apply to transactions in a spousal employer-sponsored payroll deduction plan or spousal employer-sponsored stock option plan.
Investment Clubs. These restrictions vary depending upon the person's status, as follows:
Non-Access Persons. A Non-Access Person may form or participate in a stock or investment club without prior clearance from the Chairperson of the Ethics Committee (U.S.-based personnel) or the TRP International Compliance Team (international personnel). Only transactions in Price Group stock are subject to prior transaction clearance. Club transactions must be reported just as the Non- Access Person's individual trades are reported.
Access Persons. An Access Person may not form or participate in a stock or investment club unless prior written clearance has been obtained from the Chairperson of the Ethics Committee (U.S.-based personnel) or the TRP International Compliance Team (international personnel). Generally, transactions by such a stock or investment club in which an Access Person has beneficial ownership or control are subject to the same prior transaction clearance and reporting requirements applicable to an individual Access Person's trades. If, however, the Access Person has beneficial ownership solely by virtue of his or her spouse's participation in the club and has no investment control or input into decisions regarding the club's securities transactions, the Chairperson of the Ethics Committee or the TRP International Compliance Team may, as appropriate as part of the prior clearance process, require the prior transaction clearance of Price Group stock transactions only.
Margin Accounts. While margin accounts are discouraged, you may open and maintain margin accounts for the purchase of securities provided such accounts are with firms with which you maintain a regular securities account relationship.
Limit Orders. While limit orders are permitted, Access Persons must be careful using "good until cancelled" orders keeping in mind that prior clearance is valid for three business days. Use of "day" limit orders are encouraged.
Trading Activity. You are discouraged from engaging in a pattern of securities transactions that either:
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∙Is so excessively frequent as to potentially impact your ability to carry out your assigned responsibilities, or
∙Involves securities positions that are disproportionate to your net assets.
At the discretion of the Chairperson of the Ethics Committee, written notification of excessive trading may be sent to you and/or the appropriate supervisor if ten or more reportable trades occur in your account or accounts in a month.
The following rules apply only to Access Persons other than the independent directors of the Price Funds:
Large Issuer/Volume Transactions. Although subject to prior transaction clearance, transactions involving securities of certain large issuers or of issuers with high trading volumes, within the parameters set by the Ethics Committee (the "Large Issuer/Volume List"), will be permitted under normal circumstances, as follows:
Transactions involving no more than U.S $50,000 (all amounts are in U.S. dollars) or the nearest round lot (even if the amount of the transaction marginally exceeds $50,000) per security per seven (7) calendar-day period in securities of:
∙Issuers with market capitalizations of $7.5 billion or more, or
∙U.S. issuers with an average daily trading volume in excess of 750,000 shares over the preceding 90 trading days in the U.S.
are usually permitted, unless the rating on the security has been changed within the seven calendar days immediately prior to the date of the proposed transaction. These parameters are subject to change by the Ethics Committee. An Access Person should be aware that if prior transaction clearance is granted for a specific number of shares lower than the number requested, the individual may not be able to receive permission to buy or sell additional shares of the issuer for the next seven calendar days.
Small Cap Issuer Transactions. Although subject to prior transaction clearance, transactions involving securities of certain small cap issuers may not be approved if there was a ratings change or ratings initiation in the previous 14 calendar days. Small cap issuers are defined as issuers with a market capitalization of $2.0 billion or less.
Transactions Involving Options on Large Issuer/Volume List Securities. Access Persons may not purchase uncovered put options or sell uncovered call options unless otherwise permitted under the "Options and Futures" discussion that follows. Otherwise, in the case of options on an individual security on the Large Issuer/Volume List (if it has not had a rating change), an Access Person may trade the greater of five contracts or sufficient option contracts to control $50,000 in the underlying security; thus an Access Person may trade five contracts even if this permits the Access Person to control more than $50,000 in the underlying security. Similarly, the Access Person may trade more than five contracts as long as the number of contracts does not permit him or her to control more than $50,000 in the underlying security.
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Client Limit Orders. Although subject to prior transaction clearance, an Access Person's proposed trade in a security is usually permitted even if a limit order has been entered for a client for the same security, if:
∙The Access Person's trade will be entered as a market order; and
∙The client's limit order is 10% or more away from the market price at the time the Access Person requests prior transaction clearance.
General Information on Options and Futures. If a transaction in the underlying instrument does not require prior transaction clearance (e.g., National Government Obligations, Unit Investment Trusts), then an options or futures transaction on the underlying instrument does not require prior transaction clearance. However, all options and futures transactions, except the commodity futures transactions described on page 5-9, must be reported even if a transaction in the underlying instrument would not have to be reported (e.g., U.S. Government Obligations). Transactions in publicly traded options on Price Group stock are not permitted. Please note that Contracts for Difference are treated under this Statement in the same manner as call options, and, as a result, are subject to the 60-Day Rule.
Before engaging in options and futures transactions, Access Persons should understand the impact that the 60-Day Rule and intervening client transactions may have upon their ability to close out a position with a profit (see "Closing or Exercising Options Positions").
Options and Futures on Securities and Indices Not Held by Clients of the Price Advisers. There are no specific restrictions with respect to the purchase, sale or writing of put or call options or any other option or futures activity, such as multiple writings, spreads and straddles, on a security (and options or futures on such security) or index that is not held by any of the Price Advisers' clients.
Options on Securities Held by Clients of the Price Advisers. With respect to options on securities of companies which are held by any of Price Advisers' clients, it is the firm's policy that an Access Person should not profit from a price decline of a security owned by a client (other than a "pure" Index account). Therefore, an Access Person may: (i) purchase call options and sell covered call options and (ii) purchase covered put options and sell put options. An Access Person may not purchase uncovered put options or sell uncovered call options, even if the issuer of the underlying securities is included on the Large Issuer/Volume List, unless purchased in connection with other options on the same security as part of a straddle, combination or spread strategy which is designed to result in a profit to the Access Person if the underlying security rises in or does not change in value. The purchase, sale and exercise of options are subject to the same restrictions as those set forth with respect to securities, i.e., the option should be treated as if it were the common stock itself.
Other Options and Futures Held by Clients of the Price Advisers. Any other option or futures transaction with respect to domestic or foreign securities held by any of the Price Advisers' clients will receive prior transaction clearance if appropriate after due consideration is given, based on the particular facts presented, as to whether the proposed transaction or series of transactions might appear to or actually create a conflict with the interests of any of the Price Advisers' clients. Such transactions include transactions in
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futures and options on futures involving financial instruments regulated solely by the U. S. Commodity Futures Trading Commission.
Closing or Exercising Option Positions. If you are the holder of an option and you intend to close (sell) the option or exercise the option, prior transaction clearance is required. However if you have written (sold) an option and the option is exercised against you, without any action on your part, no prior transaction clearance is required. A client transaction in the underlying security or any restriction associated with the underlying security may prevent any option transaction from being closed or exercised, therefore Access Persons should be cautious when transacting in options.
Short Sales. Short sales by Access Persons are subject to prior clearance unless the security itself does not otherwise require prior clearance. Short sale transactions in narrow, long ETFs are prohibited. In addition, Access Persons may not sell any security short which is owned by any client of one of the Price Advisers unless a transaction in that security would not require prior clearance. Short sales of Price Group stock are not permitted. All short sales are subject to the 60-Day Rule.
The 60-Day Rule. Access Persons are prohibited from profiting from the purchase and sale or sale and purchase (e.g., short sales and certain option transactions) of the same (or equivalent) securities within 60 calendar days. An "equivalent" security means any option, warrant, convertible security, stock appreciation right, or similar right with an exercise or conversion privilege at a price related to the subject security, or similar securities with a value derived from the value of the subject security. Thus, for example, the rule prohibits options transactions on or short sales of a security that may result in a gain within 60 days of the purchase of the underlying security. Any series of transactions made which violate (or are counter to) the spirit of the 60-Day Rule, such as the establishment of a long position and subsequent establishment of a short position (or vice versa), in the same (or equivalent) security, may be deemed a violation by the Ethics Committee. This prohibition is not intended to include legitimate hedging transactions. If you have questions about whether a contemplated transaction would violate the 60-Day Rule or the spirit of the Rule, you should seek an interpretation from Code Compliance prior to initiating the transaction. Violations of the 60-Day Rule will be subject to a disgorgement of profit and any other applicable sanctions. The disgorgement of profit does not take into consideration any tax lot accounting associated with the security. It is simply the calculated gain as a result of the buy and sale (or sale and purchase) within the 60-day period.
In addition, the rule applies regardless of the Access Person's other holdings of the same security or whether the Access person has split his or her holdings into tax lots. For example, if an Access Person buys 100 shares of XYZ stock on March 1 and another 100 shares of XYZ stock on November 27, he or she may not sell any shares of XYZ stock at a profit for 60 days following November 27. Similarly, an Access Person must own the underlying security for more than 60 days before entering into any options transaction on that security.
The 60-Day Rule "clock" restarts each time the Access person trades in that security.
The closing of a position in an option or Contract for Difference on any security other than an index will result in a 60-Day Rule violation if the position was opened within the 60-
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day window and the closing transaction results in a gain. Multiple positions will not be netted to determine an overall gain or loss in options on the same underlying security expiring on the same day unless the offsetting option positions were clearly part of an options strategy. Contact the Legal Compliance Employee Trading mailbox regarding the applicability of the contemplated strategy with the 60-Day Rule.
The 60-Day Rule does not apply to:
∙Any transaction by a Non-Access Person other than transactions in Price Group stock not excluded below;
∙Any transaction which because of its nature or the nature of the security involved does not require prior transaction clearance (e.g., if an Access Person inherits a security, a transaction that did not require prior transaction clearance, then he or she may sell the security inherited at a profit within 60 calendar days of its acquisition; other examples include the purchase or sale of a unit investment trust, the exercise of a corporate stock option by an
Access Person's spouse, or pro-rata distributions;
∙Any transaction in Price Group stock effected through the ESPP (note that the 60-Day rule does apply to shares transferred out of the ESPP to a securities account; generally, however, an employee remaining in the ESPP may not transfer shares held less than 60 days out of the ESPP);
∙The exercise of "company-granted" Price Group stock options or receipt of
Price Group shares through Company-based awards and the subsequent sale of the derivative shares; and
∙Any purchase of Price Group stock through an established dividend reinvestment plan.
Prior transaction clearance procedures do not check compliance with the 60-Day Rule when considering a trading request. Access Persons are responsible for checking their compliance with this rule before entering a trade. If you have any questions about whether this rule will be triggered by a proposed transaction, you should contact Code Compliance or International Compliance before requesting prior transaction clearance for the proposed trade. Access Persons may request in writing an interpretation from the Chairperson of the Ethics Committee that the 60-Day Rule should not apply to a specific transaction or transactions.
Expanded Holding Period Requirement for Employees in Japan. Securities owned by staff employed by TRPJ may be subject to a longer holding period than 60 days. If you have any questions about this restriction, you should contact International Compliance.
Investments in Non-Listed Securities Firms. Access Persons may not purchase or sell the shares of a broker-dealer, underwriter or federally registered investment adviser unless that entity is traded on an exchange or listed as a NASDAQ stock or prior transaction clearance is given under the private placement procedures.
REPORTING OF ONE HALF OF ONE PERCENT OWNERSHIP. If an employee owns more than ½ of 1% of the total outstanding shares of a public or private company, he or she must immediately report this in writing to Code Compliance (via the Code of Ethics mailbox), providing the name of the company and the total number of such company's shares beneficially owned.
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GAMBLING RELATED TO THE SECURITIES MARKETS. All associates subject to the Code are prohibited from wagering, betting or gambling related to individual securities, securities indices, currency spreads, or other similar financial indices or instruments. This prohibition applies to wagers placed through casinos, betting parlors or internet gambling sites and is applicable regardless of where the activity is initiated (e.g., home or firm computer or telephone). This specific prohibition does not restrict the purchase or sale of securities through a securities account reported to Code Compliance even if these transactions are effected with a speculative investment objective.
INITIAL DISCLOSURE OF PERSONAL SECURITIES HOLDINGS BY ACCESS PERSONS. Upon commencement of employment, appointment or promotion (no later than 10 calendar days after the starting date), each Access Person, except an independent director of the Price Funds, is required by U.S. securities laws to disclose all current securities holdings in which he or she is considered to have beneficial ownership or control ("Initial Holdings Report") (see page 5-4 for definition of the term Beneficial Owner) and provide or reconfirm the information regarding all of his or her securities accounts. Access Persons should use myTRPcompliance, located on the Exchange, to disclose and certify their Initial Holdings Report. SEC Rules require that each Initial Holding Report contain, at a minimum, the following information:
∙Securities title;
∙Securities type;
∙Exchange ticker number or CUSIP number, as applicable;
∙Number of shares or principal amount of each reportable securities in which the Access Person has any direct or indirect beneficial ownership;
∙The name of any broker, dealer or both with which the Access Person maintains an account in which any securities are held for the Access Person's direct or indirect benefit; and
∙The date the Access Person submits the Initial Holding Report.
The information provided must be current as of a date no more than 45 days prior to the date the person becomes an Access Person.
ANNUAL DISCLOSURE OF PERSONAL SECURITIES HOLDINGS BY ACCESS PERSONS. Each Access Person, except an independent director of the Price Funds, is also required to file an Annual Compliance Certification as of December 31 of each year. This report can be completed by using myTRPcompliance located on the Exchange. This report is due by no later than January 31. The Chief Compliance Officer or their designee reviews all Annual Compliance Certifications.
SANCTIONS. Strict compliance with the provisions of this Statement is considered a basic provision of employment or other association with Price Group and the Price Funds. The Ethics Committee, the Code Compliance Team, and the TRP International Compliance Team are primarily responsible for administering this Statement. In fulfilling this function, the Ethics Committee will institute such procedures as it deems reasonably necessary to monitor each person's and entity's compliance with this Statement and to otherwise prevent and detect violations.
6-27
Violations by Access Persons, Non-Access Persons and Independent Directors of Price Group. Upon discovering a material violation of this Statement by any person or entity other than an independent director of a Price Fund, the Ethics Committee will impose such sanctions as it deems appropriate and as are approved by the Management Committee or the Board of Directors including, inter alia, a letter of censure or suspension, a fine, a suspension of trading privileges or termination of employment and/or officership of the violator. In addition, the violator may be required to forfeit any profit realized from any transaction that is in violation of this Statement to the T. Rowe Price Foundation or an approved international non-profit organization. All material violations of this Statement shall be reported to the Board of Directors of Price Group and to the Board of Directors of any Price Fund with respect to whose securities such violations may have been involved.
Following are sanctions guidelines associated with violations of this Statement. These guidelines are supplemental to the forfeiture of profit associated with certain violations where an associate economically benefited. Code Compliance will utilize a rolling two- year, look-back period in the administration of the sanctions guidelines.
First Violation
∙Associate and manager notification, and
∙Associate required to complete online remedial training course.
Second Violation
∙Associate and escalated manager notifications up to, and including, applicable
Management Committee ("MC") member,
∙Associate required to complete online remedial training course,
∙Associate required to meet with applicable Chief Compliance Officer and Senior Compliance Manager, and
∙Associate fined according to officer or role guidelines.
Associate |
VP TRP Group |
Investment |
Portfolio Manager, |
|
|
Personnel |
Business Unit Leader, |
|
|
|
MC Member |
$250 |
$750 |
$750 |
$1,500 |
Third Violation
∙Associate and escalated manager notifications up to, and including, applicable
Management Committee ("MC") member,
∙Chief Executive Officer notified,
∙Associate required to complete online remedial training course,
∙Associate subject to three-month trading prohibition, and
∙Associate fined according to officer or role guidelines.
Associate |
VP TRP Group |
Investment |
Portfolio Manager, |
|
|
Personnel |
Business Unit Leader, |
|
|
|
MC Member |
$500 |
$2,000 |
$2,000 |
$5,000 |
Fourth Violation
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∙Sanctions to be determined by Ethics Committee.
Violations by Independent Directors of Price Funds. Upon discovering a material violation of this Statement by an independent director of a Price Fund, the Ethics Committee shall report such violation to the Board on which the director serves. The Price Fund Board will impose such sanctions as it deems appropriate.
6-29
T. ROWE PRICE GROUP, INC.
STATEMENT OF POLICY
ON
SYSTEMS SECURITY AND RELATED ISSUES
Purpose of Statement of Policy ("Statement"). The central and critical role of computer systems in our firm's operations underscores the importance of ensuring their confidentiality, availability, and integrity. Our data is an extremely valuable asset and should be protected by all system users. Data within the T. Rowe Price Group network should be considered proprietary and confidential and should be protected as such. This Statement should be read in conjunction with the Statement of Policy on Privacy (page 8-1).
Systems activities and information will be referred to collectively in this Statement as the "Systems". The Systems include all hardware, software, operating systems, and wired and wireless network resources involved in the business of T. Rowe Price; all information transmitted, received, logged or stored through the Systems including email, voice mail, messaging, printers, and online facsimiles; and all back-ups and records retained for regulatory or other purposes including all portable and fixed storage media and locations for storage. Information also includes any work products that are created while working at or on behalf of T. Rowe Price and are the exclusive property of T. Rowe Price unless otherwise stipulated.
The Systems also include the use of computer access, data, services and equipment provided by T. Rowe Price including any access to the Internet or via Internet; access to and use of commercial and specialized software programs and systems licensed or developed for the firm's use; access to and use of customer and T. Rowe Price business data; use of and data on T. Rowe Price desktop and portable computers, and other mobile devices such as smart phones and tablets. The use, access, or storage of data on non-T. Rowe Price equipment (including but not limited to personally owned or "home" equipment, hotel or business center-supplied devices, web and/or cloud services, and conference supplied or internet café terminals) used for T. Rowe Price business purposes is included in the definition of systems, as appropriate.
Any new device, application or methodology offered by T. Rowe Price subsequent to the date of this version of this Statement, or that comes into common use for business purposes, is also covered under this definition of T. Rowe Price Systems and information.
This Statement establishes an acceptable use policy for all Price Group Associates and all other individuals, including vendors, cloud services, service providers and contractors, with Price Group systems access.
The Statement has been designed to give associates guidelines to:
∙Maintain and protect the integrity of customer, corporate, and employee confidential information;
∙Prevent the unauthorized use of or access to our firm's computer Systems;
∙Prevent breaches and the introduction of malicious software; and
∙Respond to incidents and alert management in accordance with defined practices.
6-30
Any material violation of this Statement may lead to disciplinary sanctions, up to and including dismissal of individuals involved. Additionally, actions in violation of this Statement may constitute a crime under applicable laws.
By using the firm's Systems, you agree to be bound by this Statement and consent to the access to and disclosure of all information by the firm and do not have any expectation of privacy in connection with the use of the Systems.
SECURITY PRINCIPLES. T. Rowe Price maintains a security organization, with supporting policies, to provide guidance and direction on appropriate security controls to all associates and users. Key principles for end users or associate behavior include:
∙Security Responsibility. Security is everyone's responsibility at T. Rowe Price.
∙Suspicious Activity. Report all suspicious activity to the Help Desk immediately.
∙Authorized System Users. Access to systems is restricted to authorized users who need access in order to support their business activities. This includes systems that are External to the T. Rowe Price environment.
∙User-IDs and Passwords. Every user is assigned a unique User-ID. Each User-ID has a password that must be kept confidential by the users. Employee IDs and easily deducible information should not be used for passwords. Users will be held accountable for work performed with their User-IDs.
∙Secure Desk / Asset. Sensitive information must be secured and/or locked appropriately when unattended. This includes electronic and physical information.
∙Mobile Assets. All portable computer equipment (e.g., laptops, smart phones, flash drives) containing information that is sensitive must be encrypted and password protected where possible. In the event of loss or theft, contact the Help Desk immediately.
∙Incident Response. T. Rowe Price has the authority, at its own discretion, to disable any ID or activity as needed to respond to a security issue. Efforts will be made to contact presumed owners of these IDs as appropriate; however, IDs may be disabled as part of system or vulnerability management processes.
INTERNET ACCESS AND OTHER ONLINE SERVICES. Accessing the Internet and accessing T. Rowe Price systems from the Internet presents special security considerations due to the nature of the connection and the security concerns present in Internet services. When using Internet access or other online services, the following policies apply:
∙The use of firm Systems is intended for legitimate business purposes and individuals should limit personal use. You may not use the firm's Systems in any way that might pose a business risk or data privacy risk or in a manner that violates laws.
∙Do not use firm's Systems to access or send inappropriate content, including, but not limited to adult or gambling internet sites or to create or forward communications that could be offensive to others or embarrassing to you or T. Rowe Price.
∙T. Rowe Price may block access to internet sites or emails without prior notice based on potential risk to the firm or for other business reasons.
∙You may not access or download anything for installation or storage onto the firm's computers for personal use including, but not limited to, streaming media, videos, music, games, or messaging and mail applications.
6-31
∙T. Rowe Price Systems may not be used to remotely control, maintain, or service unauthorized computers or systems. T. Rowe Price systems may not be connected to non-T. Rowe Price networks, as this could lead to system attack/compromise and data loss. Wireless routers and/or hotspots may not be connected to the T. Rowe Price network.
∙No person or entity may contract for domain names for use by Price Group or for the benefit of Price Group without express authority from the Legal Department. Internet domain names are assets of the firm and are purchased and maintained centrally. This also includes free account registrations such as those on social networking sites and web email.
∙Only approved Systems and solutions may be used to conduct T. Rowe Price business. The independent use of other technologies, including peer-to-peer file sharing networks or software, web file storage, removeable storage devices (e.g. USB and hard drives), and Instant Messaging, are prohibited as they may not meet regulatory requirements to transfer, monitor and archive electronic communications. No personal email accounts may ever be used to send or receive business or client related communications.
∙Associates are prohibited from using personal mobile devices to conduct Price Group business activities except as defined in the Mobile Device Policy or as authorized by management. Non-public customer information may not be stored on personal mobile devices. If personal devices are used to conduct business activities, personal devices and/or content could be requested as part of an investigation or subpoena.
∙The Technology and Recovery Centers are considered sensitive locations and their location should not be publicly disclosed. If asked for their location by clients or others, please direct the inquiry to your manager or the Help Desk for evaluation.
Guidelines for Installing Software. Only approved software is authorized to be installed on Price Group systems. Any software program that is used by Price Group personnel in connection with the business of the firm must be ordered through the Help Desk. T. Rowe Price has the authority, at its own discretion; to remove any installed software, downloaded software, or any other application or executable that is not authorized for use by Price Group or may pose a security risk.
Downloading or Copying and Remote Printing. Downloading or copying software using T. Rowe Price Systems, including documents, graphics, programs and other computer-based materials, from any outside source is not permitted unless it is authorized. Downloads and copies may introduce viruses and malicious code into Systems. Downloading or uploading copyrighted materials may violate the rights of the authors of the materials, may create a liability, privacy or security breach, or cause embarrassment to the firm. Downloading or copying T. Rowe Price data or source code to an unapproved removable storage device is prohibited. Remotely printing T. Rowe Price data from any outside printer (e.g. hotel, home, etc.) is not permitted unless authorized.
PROTECTION FROM MALICOUS CODE. "Malicious code" is computer code that is designed to damage or access software or data on a computer system. T. Rowe Price manages a comprehensive malicious code prevention and control program to protect Systems and data. Introducing a virus or similar malicious code into the Price Group Systems by engaging in prohibited actions or by failing to implement recommended precautions may lead to disciplinary actions. Pranks, jokes, or other actions that simulate or trigger a system security event such as, but not limited to, a computer virus are prohibited. Users must comply with the following security practices:
6-32
∙Contact the Help Desk. Immediately contact the Help Desk for anything that appears suspicious or is identified as malicious. The Help Desk will determine whether the device is infected, the severity of the infection, and the appropriate remedial actions.
∙Be Careful when Opening Emails. Carefully review emails, attachments, or links prior to opening or accessing them, as they may contain malicious code or viruses. Report suspicious emails as soon as feasible.
∙Approved Devices. Only connect devices issued or approved by T. Rowe Price into Systems to reduce the risk of malware infections. This includes, but is not limited to, thumb drives, mobile devices such as smart phones or tablets, and gadgets/novelties powered by USB ports.
∙Maintain Security Settings. Users should not disable virus scanning features, password settings, or other security features for any reason. Failure to maintain updated scanning files is also prohibited.
∙Keep T. Rowe Price Mobile Assets Updated. Users who receive a Price Group technology asset must install updates as instructed by the Help Desk and/or connect the asset to the Price Group network on a regular basis to receive software, application, and operating system security updates.
∙Keep Personal Computer Assets Updated. Users must maintain anti-virus software, application, and operating system security updates on all non-T. Rowe Price or personally owned assets that are used to access the T. Rowe Price network. Remote devices that do not meet these requirements may be prevented from connecting to the T. Rowe Price network.
∙Report Unauthorized Network Connections. Report any attempts to create an unauthorized or foreign connection to the network to the Help Desk.
CONFIDENTIALITY OF SYSTEM ACTIVITIES AND INFORMATION. System activities and access on Price Group computers is subject to monitoring by firm personnel or others. All such information are records of the firm and the sole property of the firm. The firm reserves the right to monitor, access, and disclose for any purpose all information, including all messages sent, received, transmitted, or stored through the Systems.
Certain departments at T. Rowe Price record telephone conversations placed to and from the department (this includes but is not limited to the Call Centers and Corporate Actions Department). These recordings are made for various purposes, such as for quality review, when required by law, recording of instructions, as well as for other business reasons. Any telephone conversations placed to and from these departments (including internal calls) will be recorded and subject to monitoring.
Information, including electronic communications, entered into our firm's computers but later deleted from the Systems may continue to be maintained for applicable periods on our firm's back- up repositories or in records retained for regulatory or other purposes.
PARTICIPATION ON SOCIAL MEDIA SITES. Associates are directed to the Social Media Policy located on the Exchange to understand their responsibilities with respect to social media.
QUESTIONS REGARDING THIS STATEMENT. Please contact the Legal Department if you have any questions regarding this Statement.
6-33
6-2
T. ROWE PRICE GROUP, INC.
STATEMENT OF POLICY
ON
COMPLIANCE WITH ANTITRUST LAWS
Purpose of Statement of Policy. To protect the interests of Price Group and its personnel, Price Group has adopted this Statement of Policy on Compliance with Antitrust Laws ("Statement") to:
∙Describe the legal principles governing prohibited anticompetitive activity in the conduct of Price Group's business; and
∙Establish guidelines for contacts with other members of the investment management industry to avoid violations of the antitrust laws.
The Basic U.S. Anticompetitive Activity Prohibition. Section 1 of the U.S. Sherman Antitrust Act (the "Act") prohibits agreements, understandings, or joint actions between companies that constitute a "restraint of trade", i.e., that reduce or eliminate competition.
This prohibition is triggered only by an agreement or action among two or more companies; unilateral action never violates the Act. To constitute an illegal agreement, however, an understanding does not need to be formal or written. Comments made in conversations, casual comments at meetings, or even as little as "a knowing wink," as one case says, may be sufficient to establish an illegal agreement under the Act.
The agreed-upon action must be anticompetitive. Some actions are "per se" anticompetitive, while others are judged according to a "rule of reason."
∙Some activities have been found to be so inherently anticompetitive that a court will not even permit the argument that they have a pro-competitive component. Examples of such per se illegal activities are bid-rigging; agreements between competitors to fix prices or terms of doing business; to divide up markets in any way, such as exclusive territories; or to jointly boycott a competitor or service provider.
∙Other joint agreements or activities will be examined by a court using the rule of reason approach to see if the pro-competitive results of the arrangement outweigh the anticompetitive effects. Under certain circumstances, permissible agreements among competitors may include a buyers' cooperative, or a syndicate of buyers for an initial public offering of securities. The rule of reason analysis requires a detailed inquiry into market power and market conditions.
There is also an exception for joint activity designed to influence government action. Such activity is protected by the First Amendment to the U.S. Constitution. For example, members of an industry may agree to lobby Congress jointly to enact legislation that may be manifestly anticompetitive.
Penalties for Violating the Sherman Act. A charge that the Act has been violated can be brought as a civil or a criminal action. Civil damages can include treble damages, plus attorney's fees. Criminal penalties for individuals can include fines of up to $1,000,000 and ten years in jail, and $100 million or more for corporations. The maximum fine may be increased to twice the amount
7-1
conspirators gained from the illegal acts or twice the money lost by the victims of the crime, if either of those amounts is over $100 million.
Situations in Which Antitrust Issues May Arise. To avoid violating the Act, any discussion with other members of the investment management industry regarding which securities to buy or sell and under what circumstances we buy or sell them, or about the manner in which we market our mutual funds, other commingled vehicles, and investment and retirement services, must be made with the prohibitions of the Act in mind. In addition, any discussion with our competitors about the use of particular vendors or service providers may implicate the Sherman Act.
Trade Association Meetings and Activities. A trade association is a group of competitors who join together to share common interests and seek common solutions to common problems. Such associations are at a high risk for anticompetitive activity and are closely scrutinized by regulators. Attorneys for trade associations, such as the Investment Company Institute, are typically present at meetings of members to assist in avoiding violations.
Permissible Activities:
∙Discussion of how to make the industry more competitive.
∙An exchange of information or ideas that have pro-competitive or competitively neutral effects, such as: methods of protecting the health or safety of workers; methods of educating customers and preventing abuses; and information regarding how to design and operate training programs.
∙Collective action to petition government entities.
Activities to Avoid:
∙Any discussion or direct exchange of current information about prices, salaries, fees, or terms and conditions of sales. Even if such information is publicly available, problems can arise if the information available to the public is difficult to compile or not as current as that being exchanged.
∙Discussion of specific customers, markets, or territories.
∙Negative discussions of service providers that could give rise to an inference of a joint refusal to deal with the provider (a "boycott").
Investment-Related Discussions
Permissible Activities:
∙Buyers or sellers with a common economic interest may join together to facilitate securities transactions that might otherwise not occur, such as the formation of a syndicate to buy in a private placement or initial public offering of an issuer's stock, or negotiations among creditors of an insolvent or bankrupt company.
∙Competing investment managers are permitted to serve on creditors' committees together and engage in other similar activities in connection with bankruptcies and other judicial proceedings.
7-2
Activities to Avoid:
∙It is important to avoid anything that suggests involvement with any other firm in any threats to "boycott" or "blackball" new offerings, including making any ambiguous statement that, taken out of context, might be misunderstood to imply such joint action. Avoid careless or unguarded comments that a hostile or suspicious listener might interpret as suggesting prohibited coordinated behavior between Price Group and any other potential buyer.
Example: After an Illinois municipal bond default where the state legislature retroactively abrogated some of the bondholders' rights, several investment management complexes organized to protest the state's action. In doing so, there was arguably an implied threat that members of the group would boycott future Illinois municipal bond offerings. Such a boycott would be a violation of the Act. The investment management firms' action led to an 18-month U.S. Department of Justice investigation. Although the investigation did not lead to any legal action, it was extremely expensive and time consuming for the firms and individual managers involved.
∙If you are present when anyone outside of Price Group suggests that two or more investors with a grievance against an issuer coordinate future purchasing decisions, you should immediately reject any such suggestion. As soon as possible thereafter, notify the Legal Department, which will take whatever further steps are necessary.
Benchmarking. Benchmarking is the process of measuring and comparing an organization's processes, products and services to those of industry leaders for the purpose of adopting innovative practices for improvement.
∙Because benchmarking usually involves the direct exchange of information with competitors, it is particularly subject to the risk of violating the antitrust laws.
∙The list of issues that may and should not be discussed in the context of a trade association also applies in the benchmarking process.
∙All proposed benchmarking agreements must be reviewed by the Legal Department before the firm agrees to participate in such a survey.
Discussions with Companies
It is acceptable for Price Group personnel to have individual discussions with executives of companies whether or not Price Group advisers have invested in those companies on behalf of investment advisory clients. However, caution should be exercised when having discussions with multiple companies that are in the same industry; particularly companies in concentrated industries. It could create legal issues if an individual or entity that speaks with competing companies passes confidential or sensitive business information between or among those companies. Such indirect exchanges of information could be evidence of collusion among the competing firms and the individual or entity passing the information could be the subject of litigation alleging industry collusion. For the same reason, you should avoid discussions with executives of companies that suggest a common industry
7-3
position on a competitive issue such as prices, supply, capacity, market entry, or product development, especially that you or Price Group is suggesting or endorsing such a common position. If you have questions about the acceptable scope of discussions with companies, contact the Legal Department.
Antitrust Restrictions Related to Acquisitions, Mergers and Other Transactions
Basic Restrictions. The U.S. Clayton Act bars any corporate transaction that is likely to substantially lessen competition in a particular market. This law applies not just to mergers, but to any acquisition of stock or assets, regardless of whether it transfers ownership or control. Generally, acquisitions by Price Group and similar entities do not raise issues under the Clayton Act. However, acquisitions of shares in competing companies by active investors who may seek to alter the competitive behavior of the companies they hold can be subject to challenge under the Clayton Act.
Reporting Requirements. Acquisitions of any significant size may be reportable to government antitrust authorities. In general, acquisitions by Price Group advisers on behalf of investment advisory clients are exempt from such requirements so long as the acquisitions are made solely for investment purposes. However, if any Price Group entity or employee seeks to influence the regular business decisions of a company in which Price Group advisers have holdings, the exemption from reporting may not apply. Contact the Legal Department if you have any questions.
International Requirements. The UK, European Union ("E.U."), and several countries in the Asia-Pacific ("APAC") region have requirements based on principles similar to those of U.S. law. In many cases, the laws of the E.U. are stricter than the laws of the U.S. If you have specific questions about UK, E.U., or APAC requirements, contact the Legal Department.
Antitrust Laws Relating to Employment
The U.S. antitrust laws apply to competition among firms to hire employees. An agreement among competing employers to fix the terms of employment for potential hires or to limit employment of another's employees can subject the firm or individual to civil or criminal enforcement action.
7-4
T. ROWE PRICE GROUP, INC.
STATEMENT OF POLICY
ON
PRIVACY
Scope and Enforcement
This Policy applies to all T. Rowe Price associates, contractors and directors with respect to all operations carried out globally by T. Rowe Price which involve the processing of personal data.
It is the responsibility of every associate, contractor and director throughout T. Rowe Price to comply with this Policy. Understanding of this Policy is supported through mandatory training for associates and contractors. The principles behind the Policy also are reflected in T. Rowe Price's Code of Ethics and Conduct, acknowledgement of which is required on an annual basis. Violations of this Policy may constitute grounds for disciplinary actions, up to and including, termination of employment or removal from your position.
T. Rowe Price senior management ultimately is responsible for promoting compliance to this Policy.
Definitions
Data Breach or Incident means any breach of security leading to accidental or unlawful destruction, loss, or alteration of personal data or unauthorized disclosure of, or access to, personal data.
Personal Data means any information relating to an individual that identifies the individual or could reasonably be used to identify the individual regardless of the medium involved (e.g., paper, electronic, video or audio) or how it was obtained (e.g., from an application form or through a cookie on a website that can identify an individual). Examples of personal data include contact details, identification numbers, financial data, passwords, IP addresses, pictures, online search history, and geolocation information. As required by applicable law, it also includes sensitive personal data, such as health or medical information, government-issued identification numbers, racial or ethnic origin, political opinions, religious or similar beliefs, trade union memberships, criminal offenses, sexual life information and genetic or biometric data.
The most common sources of personal data relates to clients and associates. While the privacy/data protection laws of countries typically do not extend to entities, we apply appropriate security safeguards to protect information related to clients that are entities.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Protection Principles
T. Rowe Price's business operations shall be consistent with the following Data Protection Principles. These principles are binding across our business.
1.Lawful Processing. T. Rowe Price collects, uses, and shares personal data where we have lawful grounds and legitimate business reasons for doing so. We are subject to data protection and privacy laws within each of the jurisdictions in which we operate and we undertake to conduct our business in compliance with these laws. We also are committed to helping individuals understand what information we collect, how we use it, the circumstances under which we share it with third parties, and, as applicable, what choices they have. We explain this to clients, associates and business contacts in our privacy notices as required by applicable law. We review our privacy notices regularly to keep them up to date and to ensure they match our internal practices.
2.Purposes. We collect personal data for legitimate purposes, and we strive to collect only as much personal data as we need to achieve those purposes. Though personal data can help us improve the services we provide, we should leverage it in a manner that is compliant with applicable regulation and consistent with and proportionate to our corporate policies and goals.
3.Data Accuracy. The firm take steps to ensure that the personal data we hold is accurate, relevant, and, where necessary, kept up-to-date.
4.Data Retention. We keep personal data to comply with applicable laws and obligations and take steps to ensure the safe destruction or de-identification of personal data when it is no longer required by law to be retained or it is no longer necessary for a legitimate business purpose.
5.Rights of Individuals. T. Rowe Price is committed to addressing the privacy rights of individuals, as set forth in applicable laws, with respect to our processing of their personal data.
6.Information Security. We use appropriate technical and organizational measures to keep personal data secure and ensure its integrity, confidentiality and availability across our systems. We regularly evaluate changes in technology and changes in risk and respond as appropriate.
7.International Transfers of Personal Data. T. Rowe Price is a global business and as such we transfer personal data internationally in the normal course of business. We are committed to maintaining adequate safeguards, as required by applicable laws, to protect the personal data we transfer to a country that is not regarded as having fully equivalent data protection laws.
8.Data Protection Accountability. We are all responsible for upholding the Data Protection Principles and respecting individuals' privacy rights. We have a collective and individual duty to protect our clients', associates' and business partners' personal data. In order to create an environment of trust and to comply with applicable laws, all individuals operating within or on behalf of T. Rowe Price are required to comply with our Data Protection Principles and help us to uphold our commitments to the protection of personal data.
8-2
Roles and Responsibilities
While the Data Protection Principles apply to all of us at T. Rowe Price, stakeholders at different corporate levels within T. Rowe Price play a role in ensuring overall privacy risk management and data protection compliance.
Every business unit is responsible for:
∙Ensuring the security of the personal data it maintains.
∙Allowing access to personal data only to those who require access for their job functions.
∙Reporting any known or suspected privacy breaches or incidents promptly as required.
Every associate and contingent worker is responsible for:
∙Applying the Data Protection Principles to the collection, use, and sharing of personal data and following our policies, procedures and standards regarding privacy.
Learn how to identify personal data and report any questions to the Global Privacy Office.
Collect personal data that is directly relevant and necessary to accomplish the specified purpose(s) and retain personal data in identifiable form only for as long as is necessary to fulfill the specified purpose(s) or as otherwise required or permitted by law.
Use and share personal data consistent with the purpose(s) for which it was collected.
Ensure that personal data is accurate, relevant, and, where necessary, kept up-to-date.
Secure personal data (paper and electronic) through appropriate security safeguards against risks such as loss, unauthorized access or use, destruction, modification, or unintended or inappropriate disclosure.
Avoid accessing, collecting or storing personal data that is not necessary for your current job responsibilities.
Dispose of personal data securely. For example; by using shredders or secured shred/recycle bins provided in offices or appropriate electronic erasure.
Remember that personal data belongs to T. Rowe Price and may not be copied, transferred or otherwise removed without permission.
∙Using T. Rowe Price data and equipment appropriately and securely.
Use T. Rowe Price data, systems and equipment for legitimate business purposes only and in accordance with applicable policies, guidelines and instructions.
Use secure transmission protocols when sending personal data outside of T. Rowe Price (e.g., encrypted file transfers and not unencrypted emails or attachments).
Limit internal access to personal data to those with a genuine "need to know," and limit the amount of personal data to that which is necessary to accomplish the business purpose.
Do not install or use any unapproved software.
Manage business applications on TRP computers and telecommunications devices in accordance with this Global Privacy Policy and any separate policies of Global Technology for a particular type of device or system.
∙Reporting known or suspected data security breaches or incidents.
8-3
Report known or suspected data breaches or incidents without delay to the Help Desk (Select option 2 on Help Desk menu) and also follow any internal reporting required within your business unit. Be alert for:
oSuspicious activity related to a computer, network, or software application.
oPotential or actual loss, misuse, improper access or modification of personal data.
oThe security of any system or device containing personal data has been compromised.
oAn incident in which personal data has been accessed, used or disclosed in violation of any applicable policy.
Once submitted, the incident will be investigated, and corrective actions implemented, as necessary or as appropriate.
∙Completing required training.
Complete all required privacy and information security training.
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CODE OF ETHICS AND CONDUCT
OF
T. ROWE PRICE GROUP, INC.
AND ITS AFFILIATES
INDEX
Access Persons........................................................................................................................................... |
5-3 |
Activities, Political................................................................................................................................... |
2-11 |
Adviser Act Requirements for Supervised Persons ................................................................................... |
1-3 |
Advisory Board Membership for Profitmaking Enterprise........................................................................ |
2-5 |
Allocation Policy ....................................................................................................................................... |
2-1 |
Annual Compliance Certification .................................................................................................... |
2-1, 5-27 |
Anti-Bribery Laws and Prohibitions Against Illegal Payments ................................................................. |
2-1 |
Anti-Money Laundering ............................................................................................................................ |
2-2 |
Antitrust .............................................................................................................................................. |
2-2,7-1 |
Appropriate Conduct.................................................................................................................................. |
2-2 |
Assets, Protection of Corporate ............................................................................................................... |
2-12 |
Beneficial Ownership, Definition of .......................................................................................................... |
5-4 |
Charitable Contributions ............................................................................................................................ |
2-2 |
Circulation of Rumors.............................................................................................................................. |
2-15 |
Client Limit Orders .................................................................................................................................. |
5-24 |
Client/Vendor Company Stock, Investment in .......................................................................................... |
2-6 |
Code of Ethics and Conduct, Compliance with ......................................................................................... |
1-4 |
Code of Ethics and Conduct, Persons and Entities Subject to ................................................................... |
1-2 |
Code of Ethics and Conduct, Purpose of ................................................................................................... |
1-1 |
Code of Ethics and Conduct, Questions Regarding ................................................................................... |
1-4 |
Commodity Futures Contracts ................................................................................................................... |
5-9 |
Compliance Procedures, Funds and Federal Advisers ............................................................................... |
1-4 |
Conduct, Standards of, Price Group and its Personnel .............................................................................. |
2-1 |
Confidentiality/Privacy ....................................................................................................................... |
2-7,8-1 |
Conflicts of Interest.................................................................................................................................... |
2-4 |
Contracts for Difference .......................................................................................................................... |
5-26 |
Contributions, Political ............................................................................................................................ |
2-11 |
Corporate Assets, Protection of ............................................................................................................... |
2-12 |
Crowdfunding .......................................................................................................................................... |
5-14 |
Cryptocurrency"""""""""""""""""""""""""""""""""" 5-10 |
|
Currency Trading ..................................................................................................................................... |
5-10 |
Destruction of Records ............................................................................................................................ |
2-13 |
Donor-Advised Funds, Transactions in ..................................................................................................... |
5-9 |
Drug Policy ................................................................................................................................................ |
2-9 |
Employee Likenesses, and Information, Use of ........................................................................................ |
2-9 |
Employment of Former Government Employees ...................................................................................... |
2-9 |
Equal Opportunity...................................................................................................................................... |
2-8 |
Excessive Trading, Mutual Funds Shares .................................................................................................. |
5-2 |
Exchange-Traded Funds ("ETFs")........................................................................................................... |
5-10 |
Executor, Service as................................................................................................................................. |
2-15 |
Expense Payments and Reimbursements ................................................................................................... |
2-8 |
Fees, Referral ........................................................................................................................................... |
2-13 |
Fiduciary, Price Advisers' Status as a ................................................................................................. |
1-2,5-1 |
Financial Reporting.................................................................................................................................... |
2-8 |
ii-1
Financial Service Firms, Relationships with.............................................................................................. |
2-5 |
Front Running ............................................................................................................................................ |
5-1 |
Gambling Related to Securities Markets ................................................................................................. |
5-27 |
General Policy Statement........................................................................................................................... |
1-1 |
Gifts and Entertainment ...................................................................................................................... |
2-8,3-1 |
Global Investment Performance Standards ("GIPS") .............................................................................. |
2-12 |
Government Employees, Employment of Former ..................................................................................... |
2-9 |
Harassment and Discrimination, Policy Against ....................................................................................... |
2-9 |
Illegal Payments.................................................................................................................................. |
2-1,3-1 |
Independent Directors of Price Funds, Reporting.................................................................................... |
5-19 |
Independent Directors of Price Group, Reporting ................................................................................... |
5-21 |
Information Barrier .................................................................................................................................... |
4-9 |
Information, Release to the Press............................................................................................................. |
2-14 |
Initial Public Offerings ............................................................................................................................ |
5-13 |
Inside Information............................................................................................................................. |
2-9,4-10 |
Insider Trading and Securities Fraud Enforcement Act................................................................ |
4-1,4-3,5-1 |
Interest, Conflicts of................................................................................................................................... |
2-4 |
Investment Clubs ............................................................................................................................ |
2-10,5-22 |
Investment Personnel ................................................................................................................................. |
5-4 |
Large Issuer/Volume Transactions .......................................................................................................... |
5-23 |
Litigation, Past and Current ..................................................................................................................... |
2-10 |
Lobbying .................................................................................................................................................. |
2-12 |
Margin Accounts...................................................................................................................................... |
5-22 |
Market Timing, Mutual Fund Shares ......................................................................................................... |
5-2 |
Marketing and Sales Activities ................................................................................................................ |
2-10 |
Mutual Fund Shares, Excessive Trading of ............................................................................................... |
5-2 |
myTRPcompliance................................................................................................................................... |
5-15 |
NASDAQ Requirements............................................................................................................................ |
1-4 |
Non-Access Persons................................................................................................................................... |
5-4 |
Nonprofitmaking Organizations, Service with .......................................................................................... |
2-5 |
Options and Futures ................................................................................................................................. |
5-24 |
Outside Business Activities ..................................................................................................................... |
2-10 |
Payments, Illegal........................................................................................................................................ |
2-1 |
Personal Representative, Service as......................................................................................................... |
2-17 |
Personal Securities Holdings, Disclosure of by Access Persons ............................................................. |
5-27 |
Political Action Committee ("PAC")....................................................................................................... |
2-11 |
Political Activities and Contributions ...................................................................................................... |
2-11 |
Press, Release of Information to the ........................................................................................................ |
2-14 |
Price Funds Held on Price Platforms or Through TRP Brokerage .......................................................... |
5-12 |
Price Group Stock, Transactions in............................................................................................................ |
5-5 |
Price Group, Standards of Conduct............................................................................................................ |
2-1 |
Prior Transaction Clearance Denials, Requests for Reconsideration....................................................... |
5-16 |
Prior Transaction Clearance of Securities Transactions (other than Price Group stock) ......................... |
5-14 |
Privacy Policies and Procedures ................................................................................................................ |
8-1 |
Private Placement, Investment In............................................................................................................. |
5-14 |
Professional Designations ........................................................................................................................ |
2-12 |
Profitmaking Enterprises, Relationships with............................................................................................ |
2-4 |
Transactions in T. Rowe Price Charitable .......................................................................................... |
5-6,5-9 |
Protection of Corporate Assets ................................................................................................................ |
2-12 |
Publications.............................................................................................................................................. |
2-15 |
Quality of Services................................................................................................................................... |
2-13 |
Questions Regarding the Code................................................................................................................... |
1-4 |
Rating Changes on Security..................................................................................................................... |
5-16 |
ii-2
Record Destruction .................................................................................................................................. |
2-13 |
Record Retention ..................................................................................................................................... |
2-13 |
Referral Fees ............................................................................................................................................ |
2-13 |
Regulation FD ............................................................................................................................................ |
4-7 |
Release of Information to the Press ......................................................................................................... |
2-14 |
Reportable Funds ..................................................................................................................................... |
5-12 |
Reporting by Independent Directors of Price Group ............................................................................... |
5-21 |
Reporting by Independent Directors of the Price Funds .......................................................................... |
5-19 |
Reporting Violations ................................................................................................................................ |
2-14 |
Reporting, Financial................................................................................................................................... |
2-8 |
Reporting, Price Group Stock Transactions............................................................................................... |
5-7 |
Restricted List ............................................................................................................................................ |
4-9 |
Retention of Code ...................................................................................................................................... |
1-1 |
Retention, Record ............................................................................................................................. |
2-13,8-2 |
Rule 10b5-1................................................................................................................................................ |
4-6 |
Rule 10b5-2................................................................................................................................................ |
4-4 |
Sales and Marketing Activities ................................................................................................................ |
2-10 |
Sanctions ................................................................................................................................... |
1-1, ,5-27,4-1 |
Sarbanes-Oxley Attorney Reporting Requirements................................................................................. |
2-15 |
Sarbanes-Oxley Codes ............................................................................................................................... |
1-4 |
Sarbanes-Oxley Whistleblower Procedures............................................................................................. |
2-14 |
Section 529 College Savings Plans, Reporting ............................................................................... |
5-12,5-18 |
Securities Accounts, Notifications of....................................................................................................... |
5-17 |
Services, Quality of.................................................................................................................................. |
2-13 |
Short Sales ............................................................................................................................................... |
5-25 |
Sixty (60) Day Rule ................................................................................................................................. |
5-25 |
Social Media ............................................................................................................................................ |
2-15 |
Speaking Engagements ............................................................................................................................ |
2-15 |
Standards of Conduct of Price Group and its Personnel ............................................................................ |
2-1 |
Statement, General Policy.......................................................................................................................... |
1-1 |
Supervised Persons, Adviser Act Requirements for .................................................................................. |
1-3 |
Supervised Persons, Definition of.............................................................................................................. |
1-2 |
Supervision of Requests Regarding Charitable Contributions................................................................... |
2-2 |
Systems Security ............................................................................................................................... |
2-16,6-1 |
Temporary Workers, Application of Code to ..................................................................................... |
1-2,5-3 |
Trading Activity, Generally ..................................................................................................................... |
5-23 |
Trading Activity, Mutual Fund Shares ...................................................................................................... |
5-2 |
Trustee, Service as ................................................................................................................................... |
2-15 |
Use of Employees' Likenesses and Information ........................................................................................ |
2-9 |
Vendors, Relationships with Potential ....................................................................................................... |
2-6 |
Violations, Responsibility to Report ........................................................................................................ |
2-14 |
Waiver for Executive Officer, Reporting of .............................................................................................. |
1-4 |
Watch List.................................................................................................................................................. |
4-9 |
Whistleblower Procedures ....................................................................................................................... |
2-14 |
ii-3
Victory Capital Management Inc. Code of Ethics
Victory Capital Management Inc.
Code of Ethics
Effective July 1, 2019
Previously updated: July 1, 2018
Victory Capital Management Inc. Code of Ethics
July 1, 2019
Victory Capital Management Inc. Code of Ethics
July 1, 2019
Victory Capital Management Inc. Code of Ethics
1. INTRODUCTION
July 1, 2019
Rule 204A-1 of the Investment Advisers Act of 1940 ("Advisers Act") requires all investment advisers registered with the Securities and Exchange Commission ("SEC") to adopt codes of ethics that set forth standards of conduct and require compliance with federal securities laws. Victory Capital Management Inc. ("Victory Capital"), a registered investment adviser under the Advisers Act, and its subsidiaries, RS Investments (UK) Limited, RS Investments (Hong Kong) Limited, and RS Investment Management (Singapore) Pte. Ltd. (collectively, "Victory Capital"), have adopted this Code of Ethics ("Code"), which sets forth the standards of business conduct that are required of Victory Capital employees. As an adviser to regulated investment companies, Victory Capital also adopts this Code in adherence to Rule 17j-11 under the Investment Company Act of 1940. Officers and employees of RS Investments (Hong Kong) Limited and RS Investment Management (Singapore) Pte. Ltd. should also review the related Code supplements.
Victory Capital is an indirect, wholly owned subsidiary of Victory Capital Holdings, Inc. ("VCH"). VCH is a Delaware corporation with its Class A common stock listed on the NASDAQ Global Select Market, under the ticker symbol "VCTR." As a public company, new compliance policies were adopted by VCH. The VCH policies are in addition to the compliance program of Victory Capital. In particular, the VCH policies that apply to all Victory Capital employees include: (1) Code of Business Conduct and Ethics, (2) Corporate Communications Policy and (3) Insider Trading Policy. These policies are available through the company intranet site "Under the wing".
Victory Capital Advisers, Inc. ("VCA"), a Victory Capital affiliate, is a registered broker-dealer and principal underwriter of Victory Capital's Affiliated Funds (defined herein) and has adopted this Code in compliance with Rule 17j-1 under the Investment Company Act of 1940, as amended (the "Investment Company Act"). Victory Capital Transfer Agent, Inc., also a Victory Capital affiliate, is the registered transfer agent for USAA Mutual Fund accounts. Victory Capital employees service USAA Mutual Fund direct accounts through a dedicated Contact Center. Victory Capital is not affiliated with United Services Automobile Association ("USAA") or its affiliates.
Victory Capital employees have a responsibility to adhere to the highest ethical principles. Thus, the Code imposes obligations in addition to those required under applicable laws and regulations. The Code is a minimum standard of conduct for employees. If an employee is uncertain as to the intent or purpose of any provision of the Code, he or she should consult Victory Capital's Chief Compliance Officer ("CCO") or a member of the Compliance team.
Victory Capital recognizes the importance to its employees of being able to manage and develop their own and their dependents' financial resources through long-term investments and strategies. However, because of the potential conflicts of interest inherent in our business and our industry, Victory Capital has implemented certain standards and limitations designed to minimize these conflicts.
Victory Capital's reputation is of paramount importance; therefore, Victory Capital will not tolerate blemishes due to careless personal trading or other conduct prohibited by the Code. Consequently, Material Violations (as defined herein) of the Code may be subject to harsh sanctions. Frequent violations of the Code may result in limitations on personal securities trading or other disciplinary actions, which can include termination of employment.
1Rule 17j-1 requires that fund advisers adopt written codes of ethics and have procedures in place to prevent their personnel from abusing their access to information about the fund's securities trading, and requires "access persons" to submit reports periodically containing information about their personal securities holdings and transactions.
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Victory Capital Management Inc. Code of Ethics
2. DEFINITIONS
July 1, 2019
"Access Person" means any employee of Victory Capital or anyone deemed an Access Person by the CCO. As a matter of practice, the Board of Directors of the USAA Mutual Funds Trust, Victory Portfolios, Victory Portfolios II and Victory Variable Insurance Funds (collectively the "Victory Funds") generally consists of members who are not employees or officers of Victory Capital, or their affiliates. A director designated as a non-access director is not treated as an "access person" of Victory Capital, within the meaning of Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the "Advisers Act") and is not treated as either an "access person" or an "advisory person" of Victory Capital.
"Affiliated Funds" means any individual series portfolio of the USAA Mutual Funds Trust, Victory Portfolios, Victory Portfolios II and Victory Variable Insurance Funds, as well as other sub-advised affiliates listed in Appendix 1, each an investment company registered under the Investment Company Act.
"Automatic or Periodic Investment Plan" is a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.
"Beneficial Interest" means the opportunity, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, to profit, or share in any profit derived from, a transaction in the subject Securities. An Access Person is deemed to have a Beneficial Interest in securities owned by members of his or her Immediate Family. Common examples of Beneficial Interest include joint accounts, spousal accounts (including Non-Victory Capital Employee Compensation Programs, Non-Victory Capital Employee Stock Participation Program, and Employer-Sponsored Retirement Plan Accounts), Uniform Transfers to Minors Act accounts, partnerships, trusts and controlling interests in corporations. Any uncertainty as to whether an Access Person has a Beneficial Interest in a Security should be brought to the attention of the Compliance Department. Such questions will be resolved in accordance with, and this definition shall be interpreted in a manner consistent with, the definition of "beneficial owner" set forth in Rules 16a-1(a)(2) and (5) promulgated under the Securities Exchange Act of 1934.
"Blackout Period" means seven (7) calendar days before and three (3) calendar days after the date a client trade is executed.
"Business Entertainment" includes any social event, hospitality event, charitable event, sporting event, entertainment event, meal, leisure activity or event of like nature or purpose, and any transportation or lodging accompanying or related to such activity or event, including any entertainment activity offered in connection with an educational event or business conference, irrespective of whether any business is conducted during, or is attendant to, such activity.
"Covered Government Official" means a 1) state or local governmental official; 2) candidate for state or local office; or 3) federal candidate currently holding state or local office. A governmental "official" includes an incumbent, candidate, or successful candidate for elective office of a state or local government entity, if the office is directly or indirectly responsible for, or can influence the outcome of, the hiring of an investment adviser, or has authority to appoint any person who is directly or indirectly responsible for, or can influence the outcome of, the hiring of an investment adviser, by a state or a political subdivision of a state.
"De Minimis Security" means a security of an issuer that is a member of the S&P 500 Index, or a security with an equivalent market capitalization and liquidity to a S&P 500 security, as determined by the CCO or his designee, or an exempt ETF (see Appendix 5 ETFs Eligible for De Minimis Transaction Exemption for more information).
"Exempt Securities" means 1) direct obligations of the U.S. Government; 2) bankers' acceptances, bank certificates of deposit and commercial paper; 3) investment grade, short-term debt instruments, including repurchase agreements; 4) shares held in money market funds; 5) variable insurance products that invest in funds for which Victory Capital does not act as adviser or sub-adviser; 6) open-end mutual funds for
Copyright © 2019, Victory Capital Management Inc.
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Victory Capital Management Inc. Code of Ethics
July 1, 2019
which Victory Capital does not act as adviser or sub-adviser; and 7) investments in qualified tuition programs ("529 Plans"). Exempt Securities do not need to be pre-cleared.
"Immediate Family" means all family members who share the same household, including but not limited to, a spouse, domestic partner, parents, grandparents, children, grandchildren, siblings, step-siblings, step- children, step-parents, or in-laws. Immediate Family includes adoptive relationships and any other relationships (whether or not recognized by law) that the CCO determines could lead to conflicts of interest, diversions of corporate opportunity or create the appearance of impropriety.
"Index Access Person" means any employee who is a member of the Solutions Platform team, members of Victory Capital's trading team involved with trading on behalf of the Solutions Platform, employees who have access to trade rebalance information for index-based products or any other person designated as such by the CCO. Index Access Persons are restricted from trading equities during the rebalancing months. Index Access Person's may still trade securities, such as open-ended mutual funds and ETFs for which Victory Capital does not act as adviser or sub-adviser or other types of securities permitted by the CCO during this month.
"Initial Holdings Report" is a report that discloses all securities holdings of every Access Person, which must be submitted to the Compliance Department within ten (10) calendar days of becoming an Access Person.
"Initial Public Offering" or "IPO" means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before such registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the 1934 Act.
"Managed Accounts" means investment advisory or brokerage accounts over which an Access Person has no direct or indirect influence or control in the investment decisions or activities.
"Material Non-Public Information" or "MNPI" means information that is both material and non-public that might have an effect on the market for a security. Access Persons who possess MNPI must not act or cause others to act on such information.
"Material Violation" means any violation of this Code or other misconduct deemed material by the CCO, in conjunction with the Compliance Committee or the Victory Capital Board of Directors.
"Maximum Allowable Trades" means Access Persons are limited to 20 trades per calendar quarter across their Personal Accounts2. A trade in the same security in multiple accounts on the same day will count as one trade towards the Maximum Allowable Trades in a quarter.
"MCO" means MyComplianceOffice, which is a web-based compliance system used to track and approve employee personal trading, gifts and entertainment, political contributions, and outside business activities, store policies, and facilitate employee certifications and manage other compliance objectives.
"Personal Account" means an investment account in which an employee retains investment discretion.
"Personal Trading" or "Personal Trades" means trades or transactions by Access Persons in their Personal Accounts.
"Proprietary Fund" is a fund or product in which Victory Capital or its employees have an aggregate of 25% or more Beneficial Interest. See Appendix 1 Affiliated Funds, Proprietary Funds & Reportable Funds for more information.
"Portfolio Management Team" means all members of a portfolio management team including all research analysts, research associates, product specialists, and market traders.
2Certain exceptions apply subject to CCO approval.
Copyright © 2019, Victory Capital Management Inc.
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Victory Capital Management Inc. Code of Ethics
July 1, 2019
"Reportable Fund" means any investment company registered under the Investment Company Act for which Victory Capital is an investment adviser or a sub-adviser, or any registered investment company whose investment adviser or principal underwriter controls Victory Capital, is controlled by Victory Capital, or is under common control with Victory Capital. See Appendix 1 Affiliated Funds, Proprietary Funds & Reportable Funds for more information.
"Reportable Security" means any security that is not an Exempt Security.
"RIC" means a Regulated Investment Company.
"Short-Sell" or "Short-Selling" means the sale of a security that is not owned by the seller. Access Persons may not take a short position in a security. However, mutual funds or ETFs that correspond to the inverse performance of a broad-based index are not considered to be Short-Sales. For example, buying (long) the ProShares Short S&P500 ETF is permitted. Employees may also trade in funds that track a volatility index. Personal investments in highly concentrated funds made by Portfolio Management Team members may be prohibited if they contradict the client's recommendations. See "Contra-Trading Rule" under Section VII(C): Personal Trading Requirements and Restrictions for more information.
"Victory Capital Stock" means securities offered by VCH or any subsidiary through a registration statement that has been declared effective by the SEC (e.g. "VCTR").
3. CULTURE OF COMPLIANCE
Victory Capital's primary objective is to provide value through investment advisory, sub-advisory and other financial services to a wide range of clients, including governments, corporations, financial institutions, high net worth individuals and pension funds.
Victory Capital requires that all dealings on behalf of existing and prospective clients be handled with honesty, integrity and high ethical standards, and that such dealings adhere to the letter and the spirit of applicable laws, regulations and contractual guidelines. As a general matter, Victory Capital is a fiduciary that owes its clients a duty of undivided loyalty, and each employee has a responsibility to act in a manner consistent with this duty. All employees must actively work to avoid the possibility that the advice or services provided to clients is, or gives the appearance of being, based on the self-interests of Victory Capital or its employees and not in the clients' best interests. Violations of the Code must be reported promptly to the CCO.
Employees must act solely in the best interests their clients. Statutory and regulatory requirements impose specific responsibilities governing the behavior of personnel in carrying out their responsibilities to clients. Victory Capital and its employees must comply fully with these rules and regulations. The Legal, Compliance and Risk Department ("LCR Department") personnel are available to assist employees in meeting these requirements.
Since no set of rules can anticipate every possible situation, it is essential that Victory Capital employees and representatives obtain guidance from the CCO or Chief Legal Officer ("CLO") when unsure how to follow these rules in letter and in spirit. It is the responsibility of all employees and representatives to fully understand and comply with the Code and the policies of Victory Capital or seek guidance from the CCO. Technical compliance with the Code and its procedures will not necessarily validate an employee's actions as appropriate. Any activity that compromises Victory Capital's integrity, even if it does not expressly violate a rule, may result in further action from the CCO. In some instances, the CCO holds discretionary authority to apply exceptions under the Code. In the CCO's absence, the CLO may act in his or her place.
Victory Capital's fiduciary responsibilities apply to a broad range of investment and related activities, including sales and marketing, portfolio management, securities trading, allocation of investment opportunities, client service, operations support, performance measurement and reporting, new product development as well
Copyright © 2019, Victory Capital Management Inc.
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Victory Capital Management Inc. Code of Ethics
July 1, 2019
as personal investing activities. These obligations include the duty to avoid material conflicts of interest (and, if this is not possible, to provide full and fair disclosure to clients in communications), to keep accurate books and records, and to supervise personnel appropriately. These concepts are further described in the sections that follow.
4. POLICY STATEMENT ON INSIDER TRADING
A. Introduction
Victory Capital seeks to foster a culture of compliance and a reputation for integrity and professionalism. Victory Capital values and endeavors to protect the confidence and trust placed in us by our clients. To further that goal, this Policy Statement implements procedures to deter the misuse of MNPI in securities transactions.
The term "insider trading" is not defined in the federal securities law, but refers generally to the situation when a person trades while aware of MNPI or communicates MNPI to others in breach of a duty of trust or confidence.
While the law concerning insider trading is not static, it is generally understood that the law prohibits any of the following:
∙Trading by an insider, while aware of MNPI;
∙Trading by a non-insider, while aware of MNPI, where the information was disclosed to the non-insider in violation of an insider's duty to keep it confidential; or
∙Communicating MNPI to others in breach of a duty of trust or confidence.
Trading securities while in possession of MNPI or improperly communicating that information to others may result in stringent penalties. Criminal sanctions may include fines of up to $5,000,000, twenty years' imprisonment, or both. The civil penalty for a violator may be an amount up to three times the profit (or loss avoided) as a result of the insider trading violation, and a permanent bar from working in the securities industry. Investors may sue and seek to recover damages for insider trading violations.
Regardless of whether a regulatory inquiry occurs, Victory Capital views seriously any violation of this Policy Statement. Such violations constitute grounds for disciplinary sanctions, up to and including dismissal.
B. Scope of the Policy Statement
This Policy Statement is drafted broadly and will be applied and interpreted in a similar manner. It applies to all Access Persons and to transactions in any security participated in by Immediate Family members of Access Persons or trusts or corporations controlled by Access Persons.
Any questions relating to this Policy Statement should be directed to the CCO or his or her designee. You must notify the LCR Department immediately if you have any reason to believe that a violation of this Policy Statement has occurred or is about to occur.
C. What is Material Information?
Trading on inside information is not a basis for liability unless the information relied upon is deemed to be material. "Material" information is defined generally as information for which there is a substantial likelihood that a reasonable investor would consider it important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a company's securities. If the disclosure of that information would be expected to alter the total mix of information that is publicly available about that company, then the information is
Copyright © 2019, Victory Capital Management Inc.
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Victory Capital Management Inc. Code of Ethics
July 1, 2019
considered material. Any questions about whether information is material should be directed to a member of the LCR Department.
Material information often relates to a company's financial results and operations, including, for example, dividend changes, earning results, changes in previously released earnings estimates, significant merger or acquisition proposals or agreements, major litigation, liquidation problems, and extraordinary management developments. Information about a company could be material because of its expected effect on a particular class of the company's securities, all of the company's securities, the securities of another company, or the securities of several companies. Material information does not have to relate to a company's business. For example, in Carpenter v. U.S., the Supreme Court considered as material certain information about the contents of a forthcoming newspaper column that was expected to affect the market price of a security. In that case, a reporter for The Wall Street Journal was found criminally liable for disclosing to others the dates that reports on various companies would appear in the Journal and whether those reports would be favorable or not.
D. What is Non-Public Information?
In order for issues concerning insider trading to arise, information must not only be material, it must also be "non-public". Non-public information is information that has not been made available to investors generally. Information received in circumstances indicating that it is not yet in general circulation or where the recipient knows or should know that the information could only have been provided by an "insider" is also deemed non-public information. For non-public information to become public information, it must be disseminated through recognized channels of distribution designed to broadly reach the securities marketplace.
Facts verifying that the information is public (and therefore has become generally available) may include, for example, and without limitation, disclosure in:
∙National business and financial wire service, such as Dow Jones or Reuters;
∙National news service or newspaper, such as AP or The Wall Street Journal; or
∙Publicly disseminated disclosure document, such as a proxy statement or prospectus.
The circulation of rumors or "talk on the street", even if accurate, widespread and reported in the media, does not constitute the requisite public disclosure. In addition, the information must not only be publicly disclosed, there must also be adequate time for the market as a whole to digest the information. Material non-public information is not made public by selective dissemination. Material information improperly disclosed only to institutional investors or to a fund analyst or a favored group of analysts retains its status as "non-public" information that must not be disclosed or otherwise misused.
Partial disclosure does not constitute public dissemination. So long as any material component of the "inside" information has yet to be publicly disclosed, the information is deemed non-public and may not be misused.
E. Identifying Inside Information
Before executing any Personal Trades or trades for client accounts, employees must determine whether they have access to MNPI. If an employee believes that he or she might have access to MNPI, the following steps should be taken:
∙Report the information and proposed trade immediately to the CCO or a member of the LCR Department;
∙Do not purchase or sell the securities as Personal Trades or for clients without written clearance to do so from the CCO or a member of the LCR Department; and
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Victory Capital Management Inc. Code of Ethics
July 1, 2019
∙Do not communicate the information inside or outside of Victory Capital, other than to the LCR Department and, if necessary, your direct manager.
A member of the Compliance Department will determine whether the information is material and non- public.
F. Contact with Public Companies
Victory Capital's contacts with public companies represent an important part of its research efforts. Victory Capital may make investment decisions on the basis of the firm's conclusions formed through such contacts and analysis of publicly available information. Legal issues may arise if, in the course of these contacts, an employee becomes aware of MNPI. This could happen, for example, if a company's chief financial officer were to prematurely disclose quarterly results to an analyst, or an investor relations representative selectively discloses adverse news to a handful of investors.
G. Tender Offers
Tender offers represent a particular concern in the law of insider trading for two reasons. First, tender offer activity often produces extraordinary gyrations in the price of the target company's securities. Trading during this time period is more likely to attract regulatory attention (and produces a disproportionate percentage of insider trading cases). Second, the SEC forbids trading and "tipping" while in possession of MNPI regarding the receipt of a tender offer, the tender offeror, the target company or anyone acting on behalf of either of these parties. Employees should exercise particular caution any time they become aware of non-public information relating to a tender offer.
H. Protecting Sensitive Information
Employees are responsible for safeguarding all confidential information relating to investment research, fund and client holdings, including analyst research reports, investment meeting discussions or notes, and current fund or client transaction information, regardless whether such information is deemed MNPI. Other types of information (for example, marketing plans, employment issues and shareholder identities) may also be confidential and should not be shared with individuals outside the company unless approved by the CCO or a Victory Capital executive officer.
All Access Persons are expressly prohibited from knowingly spreading any false rumor concerning any company, or any purported market development, that is designed to impact trading in or the price of that company's or any other company's securities, and from engaging in any other type of activity that constitutes illegal market manipulation.
I.Trading in Securities Listed on Exchanges in Other Countries
Trading in securities listed on exchanges in other countries is governed by the laws of that country. Access Persons who are trading in such securities must ensure compliance with applicable law, which in all relevant cases prohibits trading on the basis of MNPI or price-sensitive information, as those terms are defined in the relevant jurisdiction.
J. Public Company Confidential Records
VCH's and Victory Capital's records must always be treated as confidential and must not be disclosed or used for any purpose at any time other than for the normal course of business. Information learned about other entities in a special relationship with VCH, such as acquisition, joint venture and partnership negotiations, is confidential and must not be disclosed without proper authorization.
At all times, Access Persons are prohibited from making any recommendation or expressing any opinion as to trading in Victory Capital Stock
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See VCH's Corporate Communications Policy and Insider Trading Policy for more information.
5. CONFLICTS OF INTEREST
A "conflict of interest" exists when a person's private interests may be contrary to the interests of clients or shareholders of Victory Capital. A conflict may arise if a Victory Capital employee takes actions or has business, financial or other interests that may make it difficult to perform his or her work objectively and effectively.
Conflicts of interest may arise, for example, if a Victory Capital employee or his or her Immediate Family member receives improper personal benefits (for example, personal loans, services, or payment for services) as a result of his or her position at Victory Capital, or gains personal enrichment or benefits through access to confidential information. Conflicts may also arise if a Victory Capital employee or an Immediate Family member holds a financial interest in a company that does business with Victory Capital or has outside business interests that may result in divided loyalties or compromised independent judgment. Conflicts may also arise when making securities investments for Proprietary Funds or Personal Accounts or when determining how to allocate trading opportunities.
Conflicts of interest can arise in many common situations, despite best efforts to avoid them. This Code does not attempt to identify all possible conflicts of interest. Literal compliance with each of the specific procedures will not shield Access Persons from liability for Personal Trading or other conduct that violates fiduciary duties to Victory Capital clients. Victory Capital employees are encouraged to seek clarification of, and discuss questions about, potential conflicts of interest. Any questions regarding a conflict of interest or potential conflict of interest should be directed to a manager, the CCO or a representative of the LCR Department.
The following areas represent many common types of conflicts of interests and the procedures to be followed; however, the list is not intended to be all-inclusive. A summary is provided for each case, but further details can be found in the related Policies and Procedures. For questions relating potential conflicts, please contact a member of the LCR Department.
A. Gifts and Entertainment
Gifts
Giving or receiving gifts or other items of value to or from persons doing business or seeking to do business with Victory Capital could call into question the independence of its judgment as a fiduciary of its clients. Accordingly, it is the policy of Victory Capital to permit such conduct only in accordance with the limitations stated herein.
Victory Capital's policies on gifts and entertainment are derived from industry practices. Employees should be aware that there are various laws and regulations that prohibit firms and their employees from giving anything of value to employees of various financial institutions in connection with attempts to obtain any business transaction with the institution, which is viewed as a form of bribery. If there is any question about the appropriateness of any particular gift, an employee should consult a member of the LCR Department.
Under no circumstances may a gift to Victory Capital or any employee be received as any form of compensation for services provided by Victory Capital or an employee. Gifts of nominal value may be given to or accepted from present or prospective customers, brokers, service providers, suppliers or vendors with whom Victory Capital has a business or potential business relationship. Victory Capital employees are required to promptly report all gifts given in excess of $50 in Victory Capital's expense reporting system (Concur). Any gifts received in excess of $50 must promptly be disclosed in MCO. Gifts from an individual or entity may not exceed $100 in aggregate value in any
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calendar year unless approval is obtained from the employee's direct manager and the LCR Department.
Gifts of up to $100 per person per year may be provided to present or prospective customers, brokers, service providers, suppliers or vendors with whom Victory Capital has a business or potential business relationship.
Additional policies concerning gifts may be applicable depending on the type of customer (e.g., ERISA, foreign, union, government officials, or Covered Government Officials).
Please refer to Victory Capital's Gifts and Entertainment Policy (F-3) for more information.
Entertainment
Employees may sponsor and participate in Reasonable and Customary Business Entertainment. Any Business Entertainment that is not Reasonable and Customary must be approved by the CCO and the employee's manager. You must accompany the persons being entertained for an entertainment activity to qualify as permissible Business Entertainment. All Business Entertainment expenses must be reported promptly in Concur, listing each attendee at the entertainment event. The receipt of Business Entertainment in excess of $50 per occurrence per employee must be disclosed promptly after each occurrence in MCO. If the client, broker, service provider, vendor or supplier is not present, the entertainment is considered a gift.
Additional policies concerning gifts and entertainment may be applicable depending on the type of customer (e.g., ERISA, foreign, union, government officials, or Covered Government Officials).
Please refer to Victory Capital's Gifts and Entertainment Policy (F-3) for more information.
B. Political Contributions
SEC regulations limit political contributions to Covered Government Officials by employees of investment advisory firms and certain affiliated companies. The SEC's "Pay-to-Play" Rule 206(4)-5 (the "Rule") prohibits advisers from receiving any compensation for providing investment advice to a government entity within two years after a contribution has been made by the adviser or one of its covered associates. The two-year time out is triggered by a political contribution to an official of a government entity. The date of the contribution starts the time out.
The Rule permits contributions of up to $350 per person for any election to an elected official or candidate for whom the individual is entitled to vote, and up to $150 per person for any election to an elected official or candidate for whom the individual is not entitled to vote. Many U.S. cities, states and other government entities have also adopted regulations restricting political contributions by associates of investment management firms seeking to provide services to a governmental entity. While contributions to candidates in federal elections would generally not raise any issues under state or local laws, contributions to state and local officials may not be approved depending on the circumstances. Prior to the commencement of employment, new employees must disclose all political contributions in the past 2 years to Human Resources. During employment, Victory Capital employees must receive approval from the LCR Department through MCO before making personal political contributions at all levels. Political contributions which require pre-approval include, but are not limited to, the following:
∙Covered Government Officials;
∙Federal candidate campaigns and affiliated committees;
∙Political Action Committees (PACs) and Super PACs; and
∙Non-profit organizations that may engage in political activities, such as 501(c)(4), 501(c)(6) organizations, and 527 organizations
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Note: U.S. national political party donations (e.g. Democratic or Republican) do not require pre- clearance.
Contributions include:
∙Monetary contributions, gifts or loans;
∙"In kind" contributions (e.g. donations of goods or services or underwriting or hosting fundraisers);
∙Contributions to help pay a debt incurred in connection with an election (including transition or inaugural expenses, purchasing tickets to inaugural events);
∙Contributions to joint fund-raising committees; or
∙Contributions made by a PAC that is controlled by an Access Person.
See Victory Capital's Political Contributions Policy (F-2) for more information.
C. Outside Business Activities
Prior to commencement of employment with Victory Capital, all Outside Business Activities ("OBAs") must be disclosed to Human Resources. During employment and prior to commencement of any new OBA, employees must fill out and submit an OBA request form in MCO. Employees are responsible for notifying the Compliance Department of any material OBA changes and must review, update and certify quarterly to their OBA activities.
Holding Political Office/Appointments
Victory Capital employees must avoid any political appointment that may conflict with the performance of his or her duties for Victory Capital. Prior written approval must be obtained from the CCO before holding political office and, if approved, must be confirmed annually through the compliance certification process. Employees must expressly remove themselves from discussions and decisions regarding Victory Capital, its products or services when Victory Capital may be a competitor for business related to their appointment.
Outside Employment or Business Activities
Employees may pursue other interests on their own time as long as the activity doesn't reflect negatively on Victory Capital and does not interfere or conflict in any way with Victory Capital or its clients. However, full-time employees of Victory Capital should consider their position to be their primary employment.
All outside business activities must be reported to and pre-approved by both the employee's direct manager and the CCO. Outside employment or business activities may be considered any activity conducted by a Victory Capital employee for another organization or business purpose that is outside the scope of the employee's job function for Victory Capital. This includes, but is not limited to, being an employee, independent contractor, consultant, sole proprietor, officer, director or partner of another organization, or being compensated by, or having the reasonable expectation of compensation from, any other person or organization as a result of any business activity outside the scope of the relationship with Victory Capital. Certain activities are not considered reportable OBAs, including any non-investment related activity that is exclusively charitable, civic, religious or fraternal and is recognized as tax exempt.
Passive investments may be exempted from the reporting and pre-approval requirement. Although passive investments are exempted from the reporting requirements under the Outside Employment or Business Activities section of this Code, they may be subject to the reporting and pre-clearance requirements that fall under the Limited Offerings and Private Placements section of this Code. Any
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questions regarding non-compensated outside employment or business activities and passive investments should be directed to the CCO.
Absent prior approval of the CCO or the Chief Executive Officer, no employee of Victory Capital may serve on the board of directors of any publicly traded company or investment company. An employee's or Immediate Family member's service on a for-profit private company's board of directors must also be pre-approved by the employee's direct manager and the CCO or CLO, and reported on the employee's annual Code certification.
All outside employment or business activities must be reported to and pre-approved by both the employee's direct manager and the CCO and reported on the employee's quarterly certification. Employees are prohibited from the commencement of any outside employment or business activities until the CCO's final approval within MCO has occurred.
In addition to these outside employment or business activity procedures, all employees who are registered representatives of VCA must also adhere to related requirements as set forth in VCA's Written Supervisory Procedures Manual.
See Victory Capital's Outside Business Activity Policy (F-4) for more information.
Bequests
A bequest is the act of leaving or giving something of value in a will. The acceptance of a bequest from a client, vendor or business partner may raise questions about the propriety of that relationship. Any potential or actual bequest in excess of $100 made to an employee by a client, vendor, or business partner under a will or trust agreement must be reported to the LCR Department. Such bequests shall be subject to the approval of the employee's manager and CCO.
D. Other Prohibitions on Conduct
In addition to the specific prohibitions detailed elsewhere in the Code, Victory Capital employees are subject to a general requirement not to engage or participate in any act or practice that would defraud Victory Capital clients. This general prohibition includes, among other things:
∙Making any untrue statement of a material fact or employing any device, scheme or artifice to defraud a client;
∙Omitting to state a material fact, or failing to provide any information necessary to properly clarify any statements made, in light of the circumstances, thereby creating a materially misleading impression;
∙Misuse of client confidential information;
∙Making investment decisions, changing internal research ratings and trading decisions other than exclusively for the benefit and in the best interest of our clients;
∙Using information about investment or trading decisions or changes in research ratings (whether considered, proposed or made) to benefit or avoid economic injury to an Access Person or anyone other than our clients.
∙Taking, delaying or failing to take any action with respect to any research recommendation, report or rating or any investment or trading decision for a client in order to avoid economic injury to an Access Person or anyone other than a client;
∙Purchasing or selling a security on the basis of knowledge of a possible trade by or for a client with the intent of personally profiting from personal holdings in the same or related securities ("front-running" or "scalping");
∙Revealing to any other person (except in the normal course of an employee's duties on behalf of a client) any information regarding securities transactions by any client or the consideration by any client of any such securities transactions; or
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∙Engaging in any act, practice or course of business that operates or would operate as a fraud or deceit on a client or engaging in any manipulative practice with respect to any client.
E.Review of Employee Communications
All correspondence related to Victory Capital's business and any client correspondence is subject to review by the LCR Department. Victory Capital is required to maintain original records of employee correspondence that is communicated on approved devices (such as through email). In addition, Victory Capital is required to monitor employee communications and compliance with Victory Capital's conflicts of interest and insider trading policies and procedures. Consequently, Victory Capital reviews or archives all employee communications, including emails and other forms of electronic communication for compliance purposes. Employees are advised that they should have no expectation of privacy regarding personal communications that are sent or received on company- provided or connected electronic devices or communication platforms, such as instant messages or emails.
Employees are prohibited from sending communications regarding Victory Capital business via any personal, non-Victory Capital email account, instant messaging, text or other method that is not captured in our archiving system. Employees may only use Victory Capital's e-mail system, instant messaging system, Bloomberg and other explicitly approved methods for business-related communications. Employees are permitted to communicate on Victory Capital's e-mail system connected through personal mobile devices such as smartphones. See Victory Capital's Corporate Information Protection and Technology Use Policy (A-8) for more information.
6.STANDARDS OF BUSINESS CONDUCT
∙Every employee has a duty to place the interests of Victory Capital client accounts first and not take advantage of his or her positions at the expense of Victory Capital or its clients.
∙Victory Capital employees must not mislead or defraud any Victory Capital clients by any statement, act or manipulative practice.
∙All personal securities transactions must be conducted in a manner to avoid any actual, potential or the appearance of a conflict of interest, or any abuse of an employee's position of trust and responsibility with Victory Capital.
∙Victory Capital employees may not induce or cause a client to take action, or not to take action, for personal benefit.
∙Victory Capital employees may not share portfolio holdings information except as permitted under Victory Capital's Disclosures of Portfolio Securities Policy (B-15) for more information.
∙Every Access Person must notify the CCO or CLO, as soon as reasonably practical, if he or she is arrested, arraigned, indicted or pleads no contest or guilty to any criminal offense (other than minor traffic violations) or if named as a defendant in any investment-related civil proceeding or any administrative or disciplinary action.
7.PERSONAL TRADING, CODE OF ETHICS REPORTING AND CERTIFICATIONS
Personal Trading is a privilege granted by Victory Capital that may be withdrawn at any time. The CCO has complete discretion over all Personal Trading activity and has no obligation to explain any denial or restriction relating thereto. Employees who violate Personal Trading restrictions may be required to disgorge any gains generated (or losses avoided) by Personal Trading. Access Persons must maintain adequate records of all Personal Trading transactions and be prepared to disclose those transactions to the LCR Department.
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A. Employee Investment Accounts
July 1, 2019
Subject to disclosure and pre-clearance requirements, Access Persons may open and maintain Managed Accounts and Personal Accounts with select brokers supported by MCO through direct electronic feeds ("Approved Brokers"). Any accounts held with a broker that is not an Approved Broker must be transferred to an Approved Broker within 90 days of the commencement of employment with Victory Capital.
On a case-by-case basis, the LCR Department may approve certain accounts held with brokers that are not on the Approved Brokers List. The LCR Department must still receive duplicate statements and confirmations directly from the broker for each of these types of accounts.
For a list of Approved Brokers see Appendix 2 Approved Brokers List. For a summary of account disclosure requirements see Appendix 3 Investment Account Disclosure. For a summary of pre- clearance requirements see Appendix 4 Reportable Securities.
Managed Accounts
Access Persons may open and maintain Managed Accounts with Approved Brokers. With the exception of IPOs and Limited Offerings, the requirements listed below under Personal Trading Requirements and Restrictions do not apply to Managed Accounts. Participation in an IPO or a private placement in a Managed Account still requires prior approval of the CCO or his or her designee.
Managed Accounts require the following:
∙They must be approved by the LCR Department prior to trading or on the next quarterly certification, whichever is sooner;
∙At the end of each quarter, all employees must certify that all Managed Accounts have been disclosed and verify all transactions are correctly reflected in MCO;
∙The employee must certify and the broker must verify that the account is truly discretionary;
∙The broker must provide to the Compliance Department duplicate confirmations or an electronic data feed of each transaction in the account;
∙Access Persons may not exercise any direct or indirect influence or control over the transactions; and
∙Access Persons must certify quarterly that they had no direct or indirect influence or control over any transactions that occurred in their Managed Accounts.
Failure to adhere to these requirements could lead to disciplinary actions and penalties up to and including termination.
Personal Accounts
Access Persons may open and maintain Personal Accounts with brokers on the Approved Brokers List. All requirements listed below under Personal Trading Requirements and Restrictions apply to Personal Accounts.
Personal Accounts require the following:
∙They must be approved by the LCR Department prior to trading or on the next quarterly certification, whichever is sooner;
∙At the end of each quarter, all employees must certify that all Personal Accounts have been disclosed and verify all Personal Trades or transactions are correctly reflected in MCO.
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Access Persons acknowledge and agree that Victory Capital may request and obtain information regarding Personal Accounts from broker-dealers. Victory Capital may use personal information, including name, address and social security numbers, to identify and verify employee accounts.
B. Employee Investment Account Reporting
Investment Account Disclosure
All Personal Accounts and Managed Accounts must be disclosed to and approved by the LCR Department prior to trading or on the next quarterly certification, whichever is sooner. New Hires may not trade in their existing accounts until they have been disclosed and approved by the LCR Department. By regulation, such disclosure must take place within 10 days of hire. Failure to comply may result in sanctions imposed by the Victory Capital Compliance Committee and/or Board of Directors.
Initial Holdings Report/Annual Holdings Report
No Personal Trading will be authorized before the LCR Department has received a completed Initial Holdings Report as part of the new hire on-boarding process. Any exceptions must be approved by the CCO. The Initial Holdings Report must be submitted to the Compliance Department within ten
(10)calendar days of becoming an Access Person. All Access Persons must submit a similar report annually to the Compliance Department. These reports must include the following information:
∙The date when the individual became an Access Person (Initial Holdings Report only);
∙The name of each Personal Account in which any securities are or could be held in the Beneficial Interest of the Access Person, and the name of the broker-dealer or financial institution holding these accounts;
∙Current holdings in private placements (or non-public offering), including private equity, hedge funds or partnerships; and
∙Each Reportable Security or Reportable Fund in which the Access Person has a Beneficial Interest, including title, number of shares, and principal amount. Holdings information must be current as of 45 calendar days before the report is submitted.
Quarterly Securities Transaction Report
At the end of each quarter, every Access Person must verify his or her Personal Trades or transactions in Personal Accounts through MCO by submitting a Securities Transaction Report ("STR") no later than 30 calendar days following the end of each calendar quarter (whether or not trades were made). The STR must include:
∙A description of any transaction in a Reportable Security or Reportable Fund effected during the preceding quarter, such as the date, number of shares, principal amount of securities involved, nature of the transaction (i.e., a buy or a sell), price, and the name of the broker- dealer or financial institution that effected the transaction; and
∙The name and number for any account established in the preceding quarter, including the name and address of the broker-dealer or financial institution where the account is held and the date it was created.
Certain transactions are exempt from the quarterly reporting requirement. See "Summary of Pre- clearance Requirements" in Appendix 4 Reportable Securities for more information.
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C. Personal Trading Requirements and Restrictions
Prohibited Securities and Transactions
July 1, 2019
Commodities, currencies (including cryptocurrencies such as Bitcoin and Ethereum), futures, options, and selling securities short are prohibited in Personal Accounts.
Investments in companies under common control of VCH are also prohibited in Personal Accounts.
Pre-clearance Requirement
Transactions that require pre-clearance are listed in Appendix 4 Reportable Securities.
For transactions that require preclearance, employees must obtain compliance approval prior to executing the transaction. Approval may only be requested by submitting a Personal Trade Pre- Clearance Request ("PTR") in MCO. Compliance approval expires at the end of the trading day approval was provided (see exception granted to Covered Persons, as defined in VCH's Insider Trading Policy).
In certain circumstances, an approved and executed Personal Trade may need to be broken or profits disgorged (e.g. a Blackout Period triggered by subsequent client trading).
Prohibition on Personal Trades Ahead of Client Pending Orders
Access Persons are prohibited from executing Personal Trades in securities where they are aware of any pending orders in such securities by any Portfolio Management Team that, if executed, would trigger a Blackout Period, create a conflict, or disadvantage a client. Adherence to the above Pre- Clearance Requirement does not provide relief from this prohibition.
Blackout Period
A Personal Trade in the same direction as a client trade during a Blackout Period is prohibited (sells in a Personal Account will be considered in the same direction of any short sells in a client account). For non-Portfolio Management Team employees, non-volitional program trades (e.g., client cash flows, subscriptions, or redemptions) will not trigger a Blackout Period.
Individual Portfolio Management Team members will only be subject to Blackout Periods triggered by client trades made by their Portfolio Management Team and any other Portfolio Management Team that shares the same office space. Individual exceptions may occur, such as when an employee works at a different location from where the client trade was made.
Access Persons who work primarily in the transfer agent Contact Center, servicing USAA Mutual Fund direct accounts, are not subject to the Blackout Period. Such persons are subject to all other provisions of the Code, including account disclosure and pre-clearance requirements.
Index Access Persons
Index Access Persons are restricted from trading equities during the rebalancing months, which generally occur in March and September. Index Access Persons may still trade securities, such as open-ended mutual funds and ETFs for which Victory Capital does not act as adviser or sub-adviser or other types of securities permitted by the CCO during this month.
Short-Term Holding Period
Personal Trading must be for investment purposes rather than for speculation. Therefore, Access Persons may not purchase and sell or sell and purchase any Reportable Securities in a Personal
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Account within sixty (60) calendar days3. Each purchase or sale of the same security has its own 60- day holding period. Excess profits (or losses avoided) as a result of violating this restriction may be subject to disgorgement.
Maximum Allowable Trades
Access Persons are limited to 20 Personal Trades per calendar quarter across their Personal Accounts3. A trade in the same security in multiple accounts on the same day will count as one trade.
De Minimis Trades
Personal Trades in De Minimis Securities (e.g. stocks in the S&P 500 index) require pre-clearance. Personal Trades under $1,000,000 in a De Minimis Security will not be subject to the Blackout Period. De Minimis Securities are subject to all other provisions of the Code.
Contra-Trading Rule
No Portfolio Management Team member may trade a security in their Personal Account in the opposite direction of a security held in any client account that he or she manages for Victory Capital unless he or she receives prior written approval from either the CCO or his or her designee. It is the responsibility of the employee to notify the CCO if he or she intends to make a Personal Trade that is contrary to a client account. Trades related to rebalancing or cash flows are not considered in the contra-trading analysis.
Small Market Capitalization Securities
Victory Capital generally discourages Personal Trading in smaller market capitalization stocks (e.g. less than $1 billion), especially any "microcap stocks", as these securities could lead to a potential conflict of interest if they are also purchased in client accounts. Personal Trading by members of a Portfolio Management Team in common holdings with Victory Capital clients, especially in low volume or low market capitalization stocks, could lead to a potential conflict of interest and therefore may be prohibited.
IPO Rule
No Access Person may directly or indirectly acquire a Beneficial Interest in any securities offered in an IPO or in an Initial Coin Offering (ICO), in a Personal Account or Managed Account, without prior approval of the CCO or his or her designee.
Limited Offerings (Private Placements)
No Access Person may acquire a Beneficial Interest in a private placement without the prior approval of the CCO or his or her designee. Prior approval is required whether investing directly or through a Personal Account or Managed Account. Private placements, such as investment in a private company, investments in a hedge fund or other private investment fund are reportable through the pre-clearance process. Subsequent capital contributions and full or partial redemptions must be pre- cleared through MCO.
Market Timing Mutual Fund Transactions
Access Persons shall not participate in any activity that may be construed as market timing of mutual funds. Specifically, no employee shall engage in excessive trading or market timing activities as described in each prospectus of a Proprietary Fund or Reportable Fund.
3Certain exceptions apply subject to CCO Approval.
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Trading in Victory Capital Stock
July 1, 2019
Victory Capital Stock (VCTR) is a Reportable Security under the Code and any transaction in VCTR in a Personal Account must be precleared. Victory employees may be eligible for certain benefits related to VCTR, such as participation in the ESPP and grants of stock options or restricted stock. Certain transactions related to these benefits will require pre-clearance. For a summary of pre- clearance requirements for VCTR see Pre-Clearance Requirements for Victory Capital Stock under Appendix 4 Reportable Securities. If an employee is uncertain whether a transaction requires pre- clearance, they should consult with the CCO or a member of the Compliance Department prior to trading.
VCTR transactions related to the above employee benefits will not trigger the Short-Term Holding Period in a Personal Account. Likewise, VCTR transactions in a Personal Account will not affect an employee's ability to exercise such employee benefits.
Covered Persons, as defined in VCH's Insider Trading Policy, will have 3 business days upon receipt of approval to effect transactions in VCTR.
D. Representation and Warranties
Each time an Access Person submits a PTR, that Access Person shall be deemed to make the following representations and warranties:
∙They are not in possession of any MNPI for the requested security;
∙They are not aware of any client trading in the same security during the previous 3 days or in the next 7 days (Blackout Period);
∙They have not traded the same position in the opposite direction, in the past 60 days (Mandatory Short-Term Holding Period);
∙For Investment Team members, they are not trading contrary to one of their client accounts (Contra-Trading).
E.Quarterly and Annual Certifications of Compliance
Each Access Person is required to certify quarterly that he or she has disclosed all reportable:
1.Gifts and entertainment;
2.Outside Business Activities;
3.Political activity and contributions;
4.All Personal Trading Accounts, including Managed Accounts; and
5.Personal Trades.
Each Access Person is required to certify annually to the following:
1.They have read, understand and complied with this Code and other related policies;
2.They have read, understand and complied with Victory Capital's Corporate Information
Protection and Technology Use Policy (A-8);
3.They have provided and verified all reportable holdings data; and
4.They have answered all additional questions and disclosures within Victory Capital's Annual Code of Ethics Certification in an accurate and truthful manner.
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F. Review Procedures
The LCR Department will maintain review procedures consistent with this Code.
G. Recordkeeping
All Code of Ethics records will be maintained pursuant to the provisions of Rule 204A-1 under the Advisers Act and Rule 17j-1 under the Investment Company. See Victory Capital's Books and Records Policy (M-13) for more information.
H. Whistleblower Provisions
If an Access Person believes that there has been a violation of this Code, he or she must promptly notify the CCO or CLO or report anonymously to the Victory Capital Ethics telephone hotline at 800- 584-9055. Access Persons are protected from retaliation for reporting violations of this Code. Retaliation or the threat of retaliation against an Access Person for reporting a violation constitutes a further violation of this Code and may lead to immediate suspension and further sanctions. See Victory Capital's Whistleblower and Reporting Suspicious Activity Policy (F-8) for more information.
Victory Capital is also responsible for communicating the Affiliated Funds' whistleblower procedures to our employees. The Affiliated Funds have implemented procedures for receiving anonymous reports of suspected or actual violations of Affiliated Funds' policies and questionable accounting, internal accounting controls, or auditing matters. Call 866-844-3863 to initiate a report regarding an Affiliated Fund.
I.Confidentiality
All information obtained from any employee shall be kept in strict confidence, except when requested by the SEC or any other regulatory or self-regulatory organization, and may otherwise be disclosed to the extent required by law or regulation. Additionally, certain information may be provided to a broker-dealer, service provider or vendor, such as employee name, social security number and home address, in order to ascertain Personal Trading activity that is required to be disclosed by an Access Person.
J. Reporting to the Board of Directors of Affiliated Funds
At least annually, Victory Capital will provide the Board of Directors of Affiliated Funds with information regarding: 1) any Material Violations under this Code and any sanctions imposed as a response to such Material Violation; and 2) certification that Victory Capital has adopted procedures necessary to prevent Access Persons from violating this Code.
8. CODE OF ETHICS VIOLATION GUIDELINES
Each Access Person is responsible for conducting his or her activities in accordance with this Code. Violations of the Code may result in applicable sanctions.
Sanctions may correlate to the severity of the violation and may take into consideration, among other things, such factors as the frequency and severity of any prior violations. The CCO may recommend escalation to the Victory Capital Board of Directors and Compliance Committee. When necessary, the Victory Capital Board of Directors may obtain input from the Compliance Committee and the CCO when determining whether such violation is a Material Violation.
The CCO holds discretionary authority to revoke Personal Trading privileges for any length of time and also reserves the right to lift Personal Trading sanctions in response to market conditions. Additionally, the CCO
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or Compliance Committee may impose a monetary penalty for any violation. The CCO will report all warnings, violations and sanctions to the Compliance Committee.
Minor Violations
∙Provided incorrect or incomplete account or trading information
∙Engaging in a pattern of discouraged or excessive trading
∙Trading without pre-clearance approval when trade would have normally been approved and additional violations did not occur
∙Failure to submit a complete or timely initial or annual holdings or securities transactions report
∙Failure to provide the Compliance Department a duplicate confirmation in a timely manner after request or notice by the Compliance Department
∙Failure to pre-clear properly an outside business activity prior to commencement of such activity
∙Failure to complete a quarterly or annual certification by due date
∙Failure to pre-clear an investment in a private placement that would have been approved
Technical Violations
∙Any pattern of a Minor Violation within a 12-month period may qualify as a Technical Violation
∙Failure to report a Personal Account
∙Trading without pre-clearance approval when trade would not have been approved
∙Trading without pre-clearance or supplied incorrect information, which may have resulted in additional violations
∙Failure to pre-clear any activity that would have been denied by the Compliance Department
∙Any willful violations of the Code, as determined by the CCO, to be more severe than a Minor Violation
Repeat Technical Violations
∙Any Technical Violation that is repeated at least two
(2) times during a 12-month period
Material Violations / Fraudulent Actions
Potential Actions
∙LCR Department may question employee and document response
∙1st violation within a 12-month period may result in a warning letter
∙CCO and Compliance Committee will be notified of all warnings and citations given to employees
∙Employee may be required to break a trade or disgorge profits from the trade
∙Any additional actions the CCO or LCR Department deem appropriate under the circumstances
Potential Actions
∙LCR Department may question employee and document response
∙LCR Department may issue a warning letter
∙Compliance Committee is notified
∙Human Resources will be notified
∙Employee may be required to break a trade or disgorge profits from the trade any such profits will be collected by Victory Capital and donated to charity
∙Temporary ban from Personal Trading for no less than 30 calendar days
∙A fine may be imposed, as determined by the CCO on a case-by-case basis
∙Any other actions deemed appropriate by the CCO or the LCR Department
Potential Actions
∙CCO may meet with employee's direct manager to discuss violation
∙Human Resources will be notified
∙Employee may be required to break a trade or disgorge profits from the trade any such profits will be collected by Victory Capital and donated to charity
∙Three (3) or more technical violations within a 12- month period may receive a citation letter, monetary fine and loss of Personal Trading privileges for no less than 90 calendar days
∙Any other actions deemed appropriate by the CCO or the LCR Department
Potential Actions
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∙Any Material Violation
July 1, 2019
∙Compliance Committee will review and recommend sanctions and penalties up to and including termination of employment
∙The Board of Directors and, when applicable, clients will be notified
∙Possible criminal sanctions imposed by regulatory authorities
∙A fine of $10,000 may be imposed by the Board of Directors
∙Any other actions deemed appropriate by the CCO, Compliance Committee or the Board of Directors
The Code of Ethics Violation Guidelines provides examples of potential Code violations and the actions that Victory Capital might take if employees are in violation of the Code; it is not intended to serve as an exhaustive list of potential Code violations or actions relating thereto. All findings of Code violations and any actions relating thereto will be made on a case-by-case basis. The CCO has discretion to interpret violations and impose various sanctions in response to such violations as deemed necessary.
Reconsideration
If an Access Person wishes to dispute a violation notice, he or she may submit a written explanation of the circumstances of the violation to the CCO. The CCO (and the CLO if escalation is deemed necessary) will review submissions on a case by case basis. The CCO and CLO are under no obligation to change any sanction that has been imposed.
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Appendix 1 Affiliated Funds, Proprietary Funds & Reportable Funds
As described in this Code, certain restrictions apply to trading in an Affiliated Fund, a Proprietary Fund and any fund sub-advised by Victory Capital. Please refer to the company's intranet site "Under the wing" for a complete list or follow one of the links below.
Affiliated Funds
For the most up-to-date list of Affiliated Victory Funds, please visit www.vcm.com.
Proprietary Funds
Pre-clearance is required before trading in one of the following Proprietary Funds, which is a fund or product in which Victory Capital or its employees have an aggregate of 25% or more Beneficial Interest:
∙Victory Munder Small Cap Growth Fund (MASCX, MYSGX), managed by Munder Capital Management
∙Victory Munder Small Cap/Mid-Cap Blend (strategy), managed by Munder Capital Management
∙Victory Trivalent Emerging Markets Small Cap Fund (MAEMX, MYEMX), managed by Trivalent Investments
Sub-Advised Funds
Victory Capital acts as sub-adviser to a number of unaffiliated registered investment companies (mutual funds). Please refer to Victory Capital Management Inc.'s ADV filed with the SEC by searching for the firm name on https://www.adviserinfo.sec.gov . ADV Part 1 contains SECTION 5.G.(3), which lists "Advisers to Registered Investment Companies and Business Development Companies". The name of the fund complex can be obtained by searching for the SEC File Number (under More Options) using EDGAR: https://www.sec.gov/edgar/searchedgar/companysearch.html . A complete list is also available on the company's intranet site "Under the wing" under the compliance tab.
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Appendix 2 Approved Brokers List
1.Employer Sponsored Retirement Plans
2.Ameriprise Financial Services
3.Charles Schwab
4.E*TRADE
5.Edward Jones
6.Fidelity Investments
7.Interactive Brokers
8.JP Morgan Chase
9.Merrill Lynch
10.Morgan Stanley
11.Northern Trust
12.Raymond James
13.RBC
14.Scottrade
15.TD Ameritrade
16.UBS
17.USAA Brokerage
18.Vanguard
19.Wells Fargo
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Appendix 3 Investment Account Disclosure
New Hires may not trade in their existing accounts until they have been disclosed and approved by the LCR Department. By regulation, such disclosure must take place within 10 days of hire. All new Personal Accounts and Managed Accounts must be reported to the LCR Department prior to trading or on the next quarterly certification, whichever is sooner. Failure to comply may result in sanctions imposed by the Victory Capital Compliance Committee and/or Board of Directors.
The below chart summarizes certain account types and their disclosure requirements. If an employee has a beneficial interest in any account identified below, they must follow the disclosure requirements. If an employee is uncertain whether an account should be disclosed or if they have a beneficial interest in an account not listed below, he or she should consult with the CCO or a member of the Compliance team.
Account Type
Initial Disclosure
Periodic Verification
All Personal Accounts
Yes
Yes
Affiliated Fund Direct Accounts
Yes
Yes
401(k) if able to hold Reportable Securities
Yes
Yes
Security Lending Accounts
Yes
Yes
Margin Accounts
Yes
Yes
Investment Club Accounts
Yes
Yes
Private Placements
Yes
No
Unaffliated Open-end Mutual Fund Direct Accounts
No
No
Retirement accounts if unable to hold Reportable Securities
No
No
529 Plans
No
No
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Appendix 4 Reportable Securities
July 1, 2019
Personal Accounts generally require employees to pre-clear transactions by submitting PTRs through MCO. See Section VI: Personal Trading Requirements and Restrictions for more information.
Summary of Pre-clearance and Reporting Requirements
The below chart summarizes the pre-clearance and reporting requirements of certain security types. If an employee is uncertain whether a transaction requires pre-clearance, he or she should consult with the CCO or a member of the Compliance team. For Victory Capital Stock, please refer to the Summary of Pre- Clearance Requirements for Victory Capital Stock provided in this Appendix.
Prohibited in Personal Accounts
Commodities
Futures
Options
Currencies, including digital currencies (e.g. Bitcoin)
Selling Securities Short
Companies under common control with VCH
Pre-clear in Managed Accounts and Personal Accounts
Initial Public Offerings (IPO)
Private placements
Pre-clear in Personal Accounts
Equities
Corporate, High-Yield, Convertible, International, and Municipal Bonds
Exchange-traded funds (ETFs), including Victory Capital ETFs
Exchange-traded notes (ETNs)
Closed-end funds
Mortgage-Backed Securities
Agency Securities (e.g. Fannie Mae, Freddie Mac etc.)
Trust preferred & traditional preferred securities
Any securities that are gifted or donated by an Access Person
Unit investment trusts
Victory Proprietary Funds (MASCX, MYSGX, MAEMX, MYEMX)
Victory Capital 401(k) transactions greater than $100,000 in a Proprietary Fund
Reportable ONLY (pre-clearance NOT required)
Approved automatic or periodic investment plans
Corporate action transactions (e.g., stock splits, rights offerings, mergers and acquisitions)
Dividend Reinvestment Plans (DRIPs) or dividend transactions
Victory or USAA Mutual Funds, unless it's a Proprietary Fund
Security lending transactions
Variable insurance products only where Victory Capital serves as adviser or sub-adviser
Exempt Securities not subject to the Code
Direct obligations of the U.S. government
Bankers' acceptances, bank certificates of deposit and commercial paper
Investment grade, short-term debt instruments, including repurchase agreements
Money market funds
Variable insurance products unless Victory Capital acts as adviser or sub-adviser
Unaffiliated open-end mutual funds
Investments in qualified tuition programs ("529 Plans"), including the USAA College Savings Plan
Physical commodity contracts
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Summary of Pre-Clearance Requirements for Victory Capital Stock (ticker "VCTR")
VCTR Transaction Description
Pre-Clear
Common Stock (Class A Shares)
Employee purchase or sale in any Personal Account (e.g. a brokerage account for the benefit
Yes
of the employee or for the benefit of the employee's Immediate Family)
Employee purchase or sale in a Managed Account approved by Compliance.
No
Employee Stock Purchase Plan (ESPP)
Purchases made pursuant to Employee Stock Purchase Plan
No
Sales of shares acquired through the Employee Stock Purchase Plan
Yes
Options
Sale of shares in the open market acquired through the exercise of any options
Yes
Same Day Sale Exercise - Sale of all shares in the open market to cover the cost of the
Yes
exercise. Remaining proceeds go to the Employee.
Sell To Cover Exercise - Sell enough shares in the open market to cover the cost of the
Yes
exercise.
Cash Exercise - Employee pays the entire cost of the exercise.
No
Withhold Shares - Victory Capital withholds shares equal to the cost of the exercise.
No
Restricted Stock (Class B Shares)
Selling restricted stock in the open market
Yes
Sell-to-cover - Sale of restricted stock in open market to cover vested shares tax liability
Yes
Cash - Cash payment to cover vested shares tax liability
No
Net - Surrender shares to Victory Capital to cover vested shares tax liability
No
10b5-1 Trading Plan
Officers of VCH required to make filings under Section 16 of the Securities and Exchange
Act of 1934, as amended, conducting trades in accordance with an approved 10b5-1 Trading
No
Plan.
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Appendix 5 ETFs Eligible for De Minimis Transaction Exemption
Trades in the following ETFs shall be considered De Minimis Trades due to their use as highly liquid cash management vehicles in various Victory Capital accounts.
Name
Symbol
CUSIP
iShares 7-10 Year Treasury Bond ETF
IEF
464287440
iShares 20+ Year Treasury Bond ETF
TLT
464287432
iShares Core MSCI EAFE ETF
IEFA
46432F842
iShares Core MSCI Emerging Markets ETF
IEMG
46434G103
iShares Core S&P 500 ETF
IVV
464287200
iShares Core U.S. Aggregate Bond ETF
AGG
464287226
iShares FTSE China 25 Index
FXI
464287184
iShares iBoxx $ High Yield Corporate Bond
HYG
464288513
iShares iBoxx $ Investment Grade Corporate Bond ETF
LQD
464287242
iShares MSCI ACWI Index Fund
ACWI
464288257
iShares MSCI China Index Fund
MCHI
46429B671
iShares MSCI Emerging Index Fund ETF
EEM
464287234
iShares MSCI EAFE Index Fund ETF
EFA
464287465
iShares MSCI Japan Index Fund ETF
EWJ
464286848
iShares MSCI India
INDA
46429B598
iShares Russell 1000
IWF
464287614
iShares Russell 2000 ETF
IWM
464287655
iShares Russell 2000 Value
IWN
464287630
iShares Russell Mid-Cap Value
IWS
464287473
SPDR Bloomberg Barclays High Yield Bond ETF
JNK
78468R622
SPDR S&P 500 ETF
SPY
78462F103
SPDR S&P MidCap 400 ETF
MDY
78467Y107
Vanguard FTSE All-World ex-US ETF
VEU
922042775
Vanguard FTSE Developed Markets ETF
VEA
921943858
Vanguard FTSE Emerging Markets ETF
VWO
922042858
Vanguard FTSE Europe ETF
VGK
922042874
Vanguard Mortgage-Backed Securities ETF
VMBS
92206C771
Vanguard Real Estate ETF
VNQ
922908553
Vanguard Short-Term Bond ETF
BSV
921937827
Vanguard Short-Term Corporate Bond ETF
VCSH
92206C409
Vanguard S&P 500 ETF
VOO
922908363
Vanguard Total Bond Market ETF
BND
921937835
Vanguard Total International Stock ETF
VXUS
921909768
Vanguard Total Stock Market ETF
VTI
922908769
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Supplement 1 -
RS Investments (Hong Kong) Limited
Code of Ethics Supplement ("Hong Kong Supplement")
The following policies and procedures are in addition to, and supersede where relevant, the policies and procedures detailed in the Code.
I.COMPLIANCE General
Compliance with all regulatory requirements is of the utmost importance to RS Investments (Hong Kong) Limited ("RSHK"). All staff members of RSHK should read and understand the content of the Code and Victory Capital's Compliance Manual (the "Compliance Manual"), and each staff member should also read and understand the content of the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission (the "Code of Conduct") and the Fund Manager Code of Conduct (the "FMCC") issued by the Securities and Futures Commission (the "SFC") where such staff member is licensed by the SFC. RSHK should at all times have at least one designated Compliance Officer. The Compliance Officer and the responsible officers who are ultimately responsible for seeking to ensure compliance by RSHK with all applicable regulatory requirements on a daily basis are identified in the RSHK Compliance Manual.
In addition, it is also the duty of all staff members of RSHK to comply with the contents of the Code and the Compliance Manual, and to observe all other regulatory requirements as applicable to them from time to time, in all their activities on behalf of RSHK. Failure to do so may result in disciplinary action.
II.PROHIBITED CONDUCT General
Every director, manager or any other person involved in the management of RSHK has a statutory obligation to take all reasonable measures from time to time to seek to ensure that proper safeguards exist to prevent RSHK from acting in a way which would result in RSHK perpetrating any market misconduct under the Securities and Futures Ordinance (the "SFO").
Market Misconduct
"Market misconduct" under the SFO means:
1.Insider dealing
2.False trading
3.Price rigging
4.Disclosure of information about prohibited transactions
5.Disclosure of false or misleading information inducing transactions stock market manipulation; and
6.Includes attempting to engage in, or assisting, counseling or procuring another person to engage in any of the above activities
Insider Dealing
See Section IV Policy Statement on Insider Trading for more information.
False Trading
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False trading attracts civil and criminal liabilities. In brief, false trading occurs when a person, in Hong Kong or elsewhere, engages in conduct intending that, or being reckless as to whether, it creates, or is likely to create, a false or misleading appearance of active trading in securities or futures contracts traded on a Hong Kong or overseas market. An on-market "wash sale" or "matched order" is presumed to create a false or misleading appearance of active trading.
Price Rigging
Price rigging attracts civil and criminal liabilities. In brief, price rigging occurs where a person, in Hong Kong or elsewhere engages, directly or indirectly, in:
1.A wash sale which maintains, increases, reduces, stabilizes or causes fluctuations in, the price of securities traded on a Hong Kong market; or
2.Any fictitious or artificial transaction or device, intending that, or being reckless as to whether, it maintains, increases, reduces, stabilizes or causes fluctuations in, the price of securities, or the price for dealing in futures contracts, traded on a Hong Kong market.
There will also be a breach where such activity is carried out in Hong Kong which affects shares and futures contracts that are traded on an overseas market.
Disclosure of Prohibited Transactions and Disclosure of False and Misleading Information
Disclosure of prohibited transactions and disclosure of false and misleading information inducing transactions attract civil and criminal liabilities. In brief, these occur when a person discloses, circulates or disseminates information:
1.To the effect that the price of securities of a corporation, or the price for dealings in futures contracts, will be maintained, reduced or stabilized because of a prohibited transaction; or
2.That is likely to induce a transaction in securities or futures contracts if the information is false or misleading.
Stock Market Manipulation
Stock market manipulation attracts civil and criminal liabilities under the laws of Hong Kong. It is prohibited when, in Hong Kong or elsewhere, a person enters into, directly or indirectly, two or more transactions in securities that by themselves or in conjunction with any other transaction increase reduce, maintain or stabilize the price of securities and with the effect of influencing the investment decisions of other persons.
Other Offenses
All Victory Capital employees, including the employees of RSHK, are prohibited from engaging in the Short- Selling of any securities, including "naked" or "uncovered," Short-Selling on the SEHK. It is a criminal offence under the SFO for a person to sell securities at or through the SEHK unless at the time of the sale he (or his client, if he acts as an agent) has a presently exercisable and unconditional right to vest the securities in the purchaser of them, or believes and has reasonable grounds to believe that he (or his client, as the case may be) has such a right.
RSHK should also note that section 171 of the SFO imposes a duty to report Short-Selling transactions (which are covered) on both the seller (as a principal, whether he is a client or an intermediary) and the intermediary (as an agent). RSHK must also observe the Securities and Futures (Short-Selling and Securities Borrowing and Lending (Miscellaneous) Rules) and the SFC's "Guidance Note on Short-Selling Reporting and Stock Lending Record Keeping Requirements" as applicable.
RSHK and the employees of RSHK shall not make any unsolicited call (unless specifically allowed under s174 of the SFO or under the Securities and Futures (Unsolicited Calls Exclusion) Rules in order to induce
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or attempt to induce another person to sell or purchase securities, futures contract or leveraged foreign exchange contract.
Other criminal offences under the SFO include:
1.Offence involving fraudulent or deceptive devices etc. in transactions in securities, futures contracts or leveraged foreign exchange trading;
2.Offence of disclosing false or misleading information inducing others to enter into leveraged foreign exchange contracts; and
3.Offence of falsely representing dealings in futures contracts on behalf of others, etc.
Other Misconduct
Prohibition on Shadowing
An employee is prohibited from replicating deliberately what the clients of RSHK trade for the purpose of making speculative profits or avoiding losses.
Prohibition on Churning or Twisting
RSHK is not permitted to generate high commission income by putting excessive orders through the client accounts.
Prohibition on Rat Trading
An employee is prohibited from rat trading, which covers deliberate trading to the disadvantage of the client. For example, a fund manager might execute a buy order and delay allocating it to the funds or accounts it manages. If the price moves up, he may allocate it to his own account or to a nominee account at the lower execution price. On the other hand, he may delay executing the order and, if the price moves down, buy it at the lower price for himself or herself and sell it to the fund or accounts that it manages.
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Supplement 2 -
RS Investment Management (Singapore) Pte. Ltd. ("RSIMS")
Code of Ethics Supplement ("Singapore Supplement")
The policies and procedures in this Singapore Supplement to the Code apply to Access Persons of RSIMS and are in addition to, and supplement, the policies and procedures detailed in the Code.
Matters set out in the relevant sections of this Singapore Supplement shall be read in conjunction, and as one, with the Code. To the extent there is any inconsistency between the Code and this Singapore Supplement, this Singapore Supplement shall prevail.
Short-Selling of Securities
All Victory Capital employees, including employees of RSIMS, are prohibited from Short-Selling any security.
Trading on Inside Information
In addition to the requirements set out in the Code, all employees of RSIMS and all members of their Immediate Family are required to comply with all applicable laws in Singapore in relation to any Securities Transactions. Such laws include but are not limited to Part XII (Market Conduct) of the Securities and Futures Act (Chapter 289 of Singapore) ("SFA") which set out prohibitions against the following conduct:
∙False trading and market rigging transactions;
∙Securities market manipulation and manipulation of prices of futures contracts and cornering;
∙The making of false or misleading statements or the dissemination of information that is false or misleading;
∙Fraudulently inducing persons to deal in securities or trade in futures contracts;
∙Employment of fraudulent or deceptive devices, or manipulative and deceptive devices;
∙Bucketing; and
∙Insider trading and tipping off.
Reporting Requirements
In addition to the Personal Account and Personal Trading requirements and restrictions set out in the Code, each employee of RSIMS who acts as a representative of RSIMS in RSIMS' capacity as the holder of a capital markets services license issued pursuant to the SFA for fund management (each a "Relevant Access Person") is required to maintain a register of his or her interests in securities (as such term is defined in section 2(1) of the SFA, the relevant extract of which is set out in the Appendix) that are listed for quotation, or quoted, on a securities exchange or recognized market operator in the prescribed Form 15 to the Securities and Futures (Licensing and Conduct of Business) Regulations (Rg 10).
Within 7 days after the date he or she acquires the interest in the relevant securities, each Relevant Access Person shall be required to enter into his or her register:
1.Particulars of securities in which such Relevant Access Person has any interest; and
2.Particulars of such interests.
Where there is any change in any interest in the securities of such Relevant Access Person, he or she shall enter particulars of the change (including the date of the change and the circumstances by reason of which the change has occurred), within 7 days after the date of the change.
All entries in the register must be kept in an easily accessible form for a period of not less than 5 years after the date on which such entry was first made. The register shall:
1. If in physical form, be kept at RSIMS's principal place of business in Singapore; or
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2.If in electronic form, be kept in such manner so as to ensure that full access to the register may be gained by the Monetary Authority of Singapore ("MAS") at RSIMS's principal place of business in
Singapore.
RSIMS is required to maintain records of the place at which the Relevant Access Persons keep their respective registers and the places at which copies of those registers are kept in Singapore. As a separate matter, RSIMS is also required to maintain a Form 15 in relation to RSIMS' own interests in the relevant Securities.
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Code of Ethics
In accordance with Rule 204A-1 of the Investment Advisers Act of 1940 and with Rule 17j-1 of the Investment Company Act of 1940, as amended, Westfield Capital Management Company, L.P. ("Westfield") has developed and implemented this Code of Ethics (the "Code") to set forth standards for business conduct and personal activities. The Code serves many purposes. Among them are to:
∙educate employees of Westfield's expectations and the laws governing their conduct;
∙remind employees that they are in a position of trust and must act with complete propriety at all times;
∙protect the reputation of Westfield;
∙guard against violations of securities laws;
∙protect Westfield's clients by deterring misconduct; and
∙establish procedures for employees to follow so Westfield can assess whether employees are complying with our ethical principles.
Key terms used throughout this Code are defined in Appendix A.
Persons Covered by the Code
All permanent Westfield employees are covered under the Code. All employees are deemed an "Access Person". Compliance will deem an Access Person also as an "Investment Person" if the person makes or participates in making investment recommendations for client accounts. Investment Persons may be required to provide additional information for certain personal activities and may be subject to additional transactional restrictions than non-Investment Persons. At any time, employees may check their status by contacting Compliance.
Temporary employees may be subject to either all or certain provisions within the Code. Compliance may also deem a temporary employee an Access Person.
Waivers to Code
The Chief Compliance Officer (the "CCO") and the Compliance Officer (the "CO") have the authority to grant written waivers of the provisions of this Code in appropriate instances. However, Westfield expects that waivers will be granted only in rare instances. Compliance will document any waivers granted. No waivers shall be granted on any provisions of the Code that are mandated by the rules and regulations of the U.S. Securities and Exchange Commission (the "SEC").
Ethical Principles
As a fiduciary for its clients, Westfield owes its clients the utmost duty of loyalty, good faith, and fair dealing. As an employee of Westfield, you are obligated to uphold these important duties. Westfield expects every employee to uphold these principles when acting on behalf of the firm or in any capacity that may affect the firm's advisory business.
∙Employees must act with honesty, integrity, and professionalism in all aspects of our business.
∙Employees are to place the interests of Westfield's clients first, at all times.
∙Employees must not take advantage of their positions or of investment opportunities that would otherwise be available for Westfield's clients.
∙Employees must treat all information concerning clients (e.g., trading, holdings, investment recommendations, and financial situations) confidential.
∙Employees must exercise independent, unbiased judgment in the investment decision-making process.
Standards of Business Conduct
The following standards govern all conduct, whether or not the conduct is covered by more specific provisions in the Code or other Westfield policies.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
Code of Ethics
∙Employees must comply with applicable federal securities laws.
∙Employees must not:
Defraud any Westfield client in any manner;
Mislead any client, including making a statement that omits material facts or passing along information that is baseless or suspected to be untrue;
Engage in any act, practice or course of conduct which operates or would operate as a fraud or deceit upon any client (e.g., creating the false appearance of active trading in client accounts);
Engage in any manipulative practice with respect to any client; or
Engage in any manipulative practice with respect to securities, including price or market manipulation. This includes rumor mongering, which is illegal and can lead to allegations of market manipulation.
∙Employees are prohibited from inappropriately favoring the interests of one client over another as it would constitute a breach of fiduciary duty.
∙Employees must not use for their own direct or indirect benefit (or the benefit of anyone other than
Westfield's clients) information about: (a)Westfield's trading or investment recommendations for client accounts, (b) our relationships with our clients, or (c) our relationships with the brokerage community. Personal securities transactions must be conducted in accordance with applicable provisions in the Code.
∙Employees must comply with the spirit and letter of the Code and other internal policies. Technical compliance with the requirements in the Code or other policies does not insulate you from scrutiny for any actions that can create the appearance of a violation or the appearance that you are circumventing the rules.
∙Employees must avoid any actual or potential conflicts of interest with Westfield's clients. Employees will be required to complete certifications or questionnaires on such matters. It is the employee's responsibility to promptly notify Compliance of any changes to their responses.
Employees must ensure that any personal activities (e.g., personal trading) conducted during work hours do not interfere (or appears to interfere) with their daily work.
Employees must disclose any family members who have senior level positions at public or private companies.
Employees must not accept from or give to clients or other business contacts any gifts or business entertainment that would present an actual or potential conflict of interest, or would be viewed as improper. (See Westfield's policy on Gifts and Business Entertainment)
Employees may not recommend, implement, or consider any securities transaction for client accounts without having disclosed any material business or personal relationship (e.g., family member is a senior employee) with or beneficial ownership or other material interest in the issuer or its affiliates, to Compliance. If Compliance deems the disclosed interest to present a material conflict, the employee may not participate in any decision-making process regarding that issuer.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
Code of Ethics
Employees must act in the best interest of Westfield's clients regarding execution and other costs paid by clients for brokerage services. This includes disclosing to Compliance any personal investment in any business or personal (e.g., family member) relationship with brokers utilized by Westfield for client transactions or research services. All employees must strictly adhere to Westfield's policies and procedures regarding brokerage services, including those on best execution, research services, and directed brokerage.
Employees must disclose to Compliance any personal investments or other interests in third party service providers if the employees negotiate or make decisions on behalf of the firm with such third party service providers. If any employee has such an interest, Compliance may prohibit the person from negotiating or making decisions regarding Westfield's business with those companies.
Employees are prohibited from making referrals to clients (e.g., attorneys, accountants) if the employee will benefit in any way.
Reporting Unethical or Illegal Behavior
If at any time an employee has knowledge of any behavior that might be viewed as unethical, illegal or in violation of internal policies, the employee must report such behavior immediately.
How to Report. To promote employee reporting, while protecting the employee and maintaining their identity in confidence, Westfield offers different methods for reporting.
∙Contact the CCO and/or CO
Employees may report actual or suspected violations by contacting the CCO and/or the CO directly (or the Chief Executive Officer if the suspected violation is by the CCO). Employees are not required to report such matters to their managers before contacting the CCO and/or CO.
∙Report through Schwab Compliance Technologies
Reports can be submitted through Schwab Compliance Technologies (https://client.schwabct.com) by clicking on Confidential Reporting Form (Whistleblower). Such reports are accessible by the CCO only. All reports are anonymous.
What to Report. Employees should report any: a) noncompliance with applicable laws, rules and regulations, or internal policies such as the Code; b) fraud or illegal acts involving any aspect of the firm's business; c) material misstatements in regulatory filings, internal books and records, client records or reports, and financial statements; d) activity that is harmful to clients; and e) material deviations from required controls and procedures that safeguard clients and the firm.
Usage of Information Provided. The CCO will take the steps deemed necessary under the circumstances to investigate relevant facts surrounding the information provided, and to take any appropriate corrective measures. Reporting employees typically will not be notified of any actions the firm is taking in response to their comments.
Guidance. Employees are encouraged to seek guidance from the CCO and/or the CO with respect to any violation and to refrain from any action or transaction that might lead to the appearance of a violation.
Confidentiality. Any report created shall be treated confidentially. Best efforts will be used to ensure that specific details of the report cannot be used to identify the reporting employee.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
Code of Ethics
Retaliation. No employee who in good faith reports a suspected unethical or illegal business practice will be subject to retaliation or discipline for having done so, even if such reports ultimately establish that no violation had occurred.
SEC Whistleblower Program
Westfield encourages employees to report unethical or illegal behavior to the firm first, but employees also have an option of directly reporting actual or suspected violations to the SEC's Whistleblower Office. The SEC offers awards and incentives to individuals who voluntarily provide original information that leads to a successful enforcement. There are very specific criteria and procedures that apply when making such a report to the SEC. Regardless of the employee's reporting method, Westfield will utilize the framework described directly above with regards to reported information.
The SEC encourages individuals to submit information in writing by filling out their questionnaire at https://denebleo.sec.gov/TCRExternal/disclaimer.xhtml . Alternatively, you may submit information by mail to the Office of the Whistleblower at 100 F Street, NE, Mail Stop 5971, Washington, D.C. 20549 or by fax to (703) 813-9322.
Employees have the option to directly report actual or suspected violations to the SEC during and after their employment with Westfield.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Personal Trading
(All references to Access Persons in this section include family members.)
Preclearance Requirement
Access Persons must obtain approval from Compliance prior to entering into any personal securities transactions in a Covered Security for a Covered Account, as defined in Appendix A. Written approval must be received prior to executing any personal security transaction.
With limited exceptions, approvals are valid until 4:00pm on the day they were granted. Approvals for certain transactions (e.g., private offering of securities) may be extended with the CCO's or the CO's permission. In such instances, the approval is valid until either the transaction is executed or revoked by Compliance. Access Persons are responsible for notifying Compliance when the transaction has been either completed or cancelled.
Because Westfield primarily supervises domestic growth equities, certain transactions and securities pose minimal conflicts with our clients. As such, the following securities also are exempt from the preclearance requirement. (Reporting requirements still apply). If a security or transaction is not listed directly below or excluded from the Covered Security definition in Appendix A, then it must be precleared.
∙ETFs and ETNs that are not short the market, a sector, industry, etc.
∙Closed-end mutual funds
∙Gifting or transferring shares from one account to another
∙Municipal bonds
Submitting Preclearance Requests
Preclearance requests for securities transactions should be submitted through the online personal transactions system, Schwab Compliance Technologies (the "personal trading system"). Compliance will set up each Access Person in the system and provide training. It is important that Access Persons not share their passwords with anyone as they are responsible for the information created, modified, and deleted from the system under their login information.
Should an Access Person wish to make a personal security transaction but does not have access to the system, the person must contact a senior member of Compliance for preclearance of the transaction. Compliance will enter the transaction into the system, which will send an approval or denial, via email, to the requestor. It is the Access Person's responsibility to ensure that the trade information contained in the email confirmation is complete and accurate (i.e., transaction type, shares requested, brokerage account, and security name) prior to entering into the transaction.
Private Offerings
Any requests to enter into private offerings of securities must be first discussed with a senior member of Compliance. At a minimum, Compliance will request a copy of the offering documents, if applicable and available, in order to obtain the security/issuer name, investment amount, and target investment date. If the transaction is approved, Compliance will set up the security in the personal trading system, and the employee may then submit the preclearance request. Access Persons must receive a written approval (either from the personal trading system or email from Compliance) before entering into the transaction.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Reviewing Preclearance Requests
Preclearance requests are not reviewed until after 9:30am. Preclearance requests submitted prior to 9:30am will be placed in pending status. Preclearance requests that go into pending after 3:00pm will be reviewed on a best efforts basis. If a response is not received by 4:00pm, Access Persons are not permitted to enter into the trade and must re-enter the preclearance request the following day.
Compliance has full authority to:
∙revoke a preclearance any time after it is granted;
∙require an Access Person to close out or reverse a transaction; and
∙not provide an explanation for a preclearance denial or revocation, especially when the reasons are confidential in nature.
Restrictions to Personal Securities Transactions
The following restrictions and limitations have been placed on personal securities transactions to address actual or possible conflicts arising from personal trading activities.
∙Material, Non-public Information. Access Persons who possess or have been made aware of material, non-public information regarding a security, or the issuer of a security may not engage in any transaction of such security or related security. (See Westfield's policy on Insider Trading.)
∙Market Manipulation. Access Persons may not engage in any transactions intended to raise, lower, or maintain the price of any security.
∙Market Timing and Excessive Trading. Access Persons must not engage in excessive trading or market timing activities with respect to any mutual fund. When placing trades in any mutual fund, whether the trade is placed directly in a personal account, 401(k) account, deferred compensation account, account held with an intermediary or any other account, Access Persons must comply with the rules set forth in the fund's prospectus and SAI regarding the frequency and timing of such trades.
∙Transactions with Clients. Access Persons are prohibited from knowingly selling to, or purchasing from, a client any security or other property, except publiclytraded securities issued by such client.
∙Transactions Likely to Raise Conflicts with Duties to Clients. Access Persons may not enter into any transactions that: a) may have a negative impact on their attention to their responsibilities to the firm or our clients (e.g., trading frequently in personal accounts), or b) overextend their financial resources or commit them to financial liability that they are unable to meet.
∙Derivatives, Warrants and Rights. Access Persons are prohibited from trading options, forwards, swaps, warrants, rights and any other similar security in their Covered Accounts.
∙Private and Limited Offerings (e.g., IPOs). Typically, if client accounts are participating in a private or limited offering, Access Persons may not participate in the same offering. With prior approval from the CCO or CO, Access Persons may participate alongside client accounts but the client's interest will always come first. This includes Access Persons invested in Westfield's LPs (e.g., Micro Cap Fund).
∙Short Selling and Short ETFs/ETNs. Access Persons are prohibited from short selling securities in their Covered Accounts. This applies to ETFs/ETNs that are short the market, a sector, industry, etc.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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∙30-Day Holding Period. Covered Security investments made in Covered Accounts must be held for a minimum period of 30 calendar days after purchase (day one starts one day after trade date). ETFs and ETNs are not subject to the 30-day holding period.
Investment Team Sales in Covered Securities
All analysts (defined as sector and research analysts) that own securities in their covered accounts that overlap with their sector universe and are owned in a Westfield strategy managed by Westfield's Investment Committee must hold such security or securities until they have been fully liquidated from all strategies. Once the security is fully liquidated, the analyst may sell their personal shares 5 business days following the last client sale.
All individual portfolio managers that own securities in their covered accounts that overlap with the individual portfolios that they manage, must hold such security or securities until they have been fully liquidated from all client accounts under their management. Once the security is fully liquidated; the portfolio manager may sell their personal shares 5 business days following the last client sale.
The above restrictions do not apply to securities that are held due to client restrictions (e.g., tax considerations, retention for proxy voting, etc.). Any exceptions must be approved by the CCO or a designee. Analysts may continue to trim and/or sell securities for their covered accounts that are not in their sector universe. Portfolio managers may continue to trim/sell securities for their covered accounts that are not held in the portfolios they manage. Any trims/sales will still follow the above personal securities transaction restrictions, front running and blackout periods as applicable.
Front Running and Blackout Periods
Front running is an illegal practice. Access Persons should not enter into a personal security transaction when the Access Person knows, or has reason to believe, that the security or related security: a) has recently been acted upon, b) may in the near future be recommended for action, or c) may in the near future be acted upon by the firm for client accounts.
∙For Covered Securities that have been traded in client accounts, the blackout period begins five business days before the client trade and ends five business days after the last client trade. If the Covered Security was traded for reasons outside of an investment recommendation (e.g., cash flow, rebalancing/dispersion, etc.), the blackout period begins when the trades are placed on the blotter and ends when the trades have been completed.
∙For Covered Securities that have been recommended or are "under consideration," the blackout period begins five business days before the day a security was recommended or placed under consideration and typically ends five business days thereafter. Some securities may remain on the restricted list for longer periods of time. Compliance has full discretion to decide whether a security is restricted and for how long.
∙ETFs and ETNs are not subject to the blackout periods discussed in this section.
New Employees
All new employees will be required to be in compliance with Westfield's Code within 10 calendar days from their date of hire (e.g., must cover short positions).
New investment team employees will be allowed 10 calendar days to trim/liquidate securities within their sector universe that overlap with a strategy managed by Westfield's Investment Committee. However, all other provisions within the Code must be followed (e.g., must follow preclearance requirements, blackout periods apply).
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Initial 401(k) allocations, including open-end mutual Funds sub-advised or advised by Westfield do not require preclearance.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Reporting Requirements for Personal Securities Transactions
Unless noted in Exemptions in this section, Access Persons must file the reports described below, even if the person has had no holdings, transactions or accounts to list in the reports.
Reports are submitted through the personal trading system, which will track the dates and times of submissions. All submissions will remain confidential and will not be accessible by anyone other than Compliance and to the extent necessary to implement and enforce the provisions of the Code or to comply with regulatory or legal requirements.
Access Persons are responsible for reviewing and verifying the information on all of their reports prior to submission. You must promptly speak with Compliance about any errors, omissions or discrepancies on these reports before they are submitted.
Initial and Annual Holdings Reports. Access Persons must submit a report of their holdings in Covered Securities within 10 days after the day they become an Access Person and on an annual basis thereafter. Initial holdings information should be current as of a date no more than 45 days prior to the employee's date of becoming an Access Person. Annual holding reports should be as of December 31st and submitted within 30 days after the calendar year end. For each holding, Access Persons must provide: 1) the title and type of security, 2) as applicable, the exchange ticker symbol or cusip number, 3) the number of shares and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership, 4) the name of any broker, dealer or bank with which the access person maintains an account in which any securities are held for the access person's direct or indirect benefit, and 5) the date the access person submits the report.
Quarterly Transaction Reports. Access Persons are required to report Covered Securities transactions for the most recent calendar quarter. Each transaction should indicate: 1) the date of the transaction, the title, and as applicable the exchange ticker symbol or cusip number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved, 2) the nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition), 3) the price of the security at which the transaction was effected, 4) the name of broker, dealer or bank with or through which the transaction was effected, and 5) the date the access person submits the report. Quarterly transaction reports are due within 30 days after the calendar quarter end.
Initial Investment Account Reports. Access Persons must submit brokerage statements for all accounts held for their direct or indirect benefit within 10 days after the day they become an Access Person. Compliance will review these statements and determine if the accounts would fall under ongoing reporting requirements (i.e., a Covered Account). Statements should be dated no later than 45 days prior to the employee becoming an Access Person.
Quarterly Investment Account Reports. Access Persons must certify to a list of their Covered Accounts (as defined in Appendix A). Quarterly account reports are due within 30 days after the calendar quarter end.
Access Persons must notify Compliance of any new and closed Covered Accounts as soon as reasonably possible. Closed accounts will remain active in the personal trading system and will be subject to applicable reporting requirements described above, unless Compliance has been notified otherwise.
Duplicate Statements or Confirms. Duplicate copies of personal transaction confirmations or account statements are required for Covered Accounts. Copies of such documents must be sent directly to Compliance or through an electronic feed into the personal trading system. Employees with accounts set up to receive electronic feeds in the personal trading system are not required to provide paper copies of confirmations or statements as transactions and positions directly feed into the system. If Compliance does not receive the
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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appropriate electronic data or duplicate confirmations and statements, Compliance will request the documents from the Access Person. This requirement does not satisfy the quarterly or annual reporting requirements outlined above.
Private Investments. A confirmation of the investment with the invested dollar amount must be submitted to Compliance promptly after the investment is made.
Exemptions
The following transactions are exempt from the preclearance and/or reporting requirements discussed previously. Access Persons should be reminded that these exemptions do not absolve them from violations of other Westfield policies, applicable laws and regulations, as well as the spirit of the Code.
∙No Knowledge or Control. Transactions where the Access Person has no influence, control or knowledge are exempt from preclearance (e.g., corporate or broker actions).
Subject to Compliance approval, Access Persons can omit any report with respect to securities held in accounts over which the Access Person had no direct or indirect influence or control.
∙Managed Accounts. Transactions effected in accounts managed by an external financial adviser are exempt from preclearance and reporting requirements. Access Persons may speak to their adviser about their financial goals and objectives, but they are not permitted to consult with their adviser (or be consulted) on any specific security transactions. To qualify for this exemption, Access Persons must:
Have their financial adviser provide an initial written certification to Westfield on the arrangement and/or provide a copy of the managed account agreement with their financial adviser.
Complete certifications quarterly regarding their influence or control over these accounts.
Annually have their financial adviser provide a written certification to Westfield that they did not consult with their adviser on any specific security transactions and that the adviser did not consult with them on any specific security transactions.
If requested, provide Compliance with copies of holdings and/or transactions made in their account(s).
∙529 Plans or College Savings Plans. Transactions in 529 Plans or college savings plans are exempt from preclearance and reporting requirements. (Does not apply to Coverdell ESAs that are invested in Covered Securities.)
∙Automatic Investment Plans. Transactions effected pursuant to an automatic investment plan are exempt from preclearance and reporting requirements.
∙Prior Employer's Profit Sharing or Retirement Plans. Transactions executed in a prior employer's profit sharing or retirement plan are exempt from preclearance and reporting. This exemption does not apply to transactions in reportable securities or to any discretionary brokerage account option that may be available from a former employer. Such transactions/accounts are subject to preclearance and reporting requirements.
∙Other. Transactions in securities determined by Compliance to present a low potential for impropriety or the appearance of impropriety may be exempt from transactional restrictions and preclearance/reporting requirements. Compliance will review these on a case-by-case basis.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Administration
Approval and Distribution
Compliance will distribute the Code (either as a stand-alone document or as part of the firm's Compliance Manual) to all employees during the first week of hire and at least annually thereafter. Employees are required to acknowledge their having received, read, and complied with the Code.
Material amendments or material revisions made to this Code will be approved by the CCO and the Management Committee. Upon approval, the Code will be distributed to all employees shortly thereafter. Immaterial amendments do not require Management Committee approval and will be distributed either with material amendments or during the annual distribution period. Employees may be required to complete appropriate acknowledgements after distribution.
Training and Education
Compliance is responsible for coordinating the training and education of employees regarding the Code. All newly hired employees are required to complete a compliance overview session that includes a review of the Code. They also are required to acknowledge that they have attended the new employee training and have received a copy of the Code (as part of the firm's Compliance Manual). Temporary or contract employees will be required to sign a confidentiality agreement and attend a compliance overview session.
Employees are required to attend all training sessions and read any applicable materials that Compliance deems appropriate. On occasion, it may be necessary for certain departments or individuals to receive additional training. Should this be the case, a member of Compliance will coordinate with the appropriate department managers to discuss particular topics and concerns to address at the training session.
Personal Transactions Monitoring
On at least a quarterly basis, a member of Compliance will review and monitor required reports for conformity with all applicable provisions outlined in the personal trading section. Each member of the Compliance Department will review and monitor each other's reports as required by the Code.
Annual Review of Code
The CCO and/or the CO will review, at least annually, the adequacy of the Code and the effectiveness of its implementation. Such results are usually recorded in the firm's annual testing program.
Reports to Management Committee
At least annually, the CCO will report material Code matters to Westfield's Management Committee. On occasion, the CCO will also report immaterial items to the Management Committee in order to keep them informed of Code matters.
Recordkeeping Requirements
Westfield will maintain the following records in a readily accessible place for a period of not less than seven years.
∙A copy of each Code that is in effect, or at any time within the past seven years;
∙A record of any violation of the Code, and of any action taken as a result of the violation, for seven years after the end of the fiscal year in which the violation occurred;
∙A copy of each report and acknowledgement made under the Code for the past seven years after the end of the fiscal year in which the report is made or information is provided;
∙A list of names of persons, currently or within the past seven years, who are or were Access Persons or Investment Persons;
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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∙A record of any decision, and the reasons supporting the decision, for approving the acquisition of IPOs and limited offerings for at least seven years after the end of the fiscal year in which the approval was granted; and
∙A record of any granted waivers or exceptions, and supporting reasons, to any provisions of the Code.
Violations and Sanctions
Westfield treats violations of the Code (including violations of the spirit of the Code) very seriously. If an employee violates either the letter or the spirit of this Code, Westfield may impose disciplinary actions or fines, or it may make a civil or criminal referral to appropriate regulatory entities. (Refer to Appendix B for the sanctions table) Code violations become a part of the employee's employment history at Westfield. Multiple violations within a 12-month period will be reported to Human Resources and appropriate supervisors or managers. Employees should always consult with the CCO or the CO if they are in doubt of any of the requirements or restrictions in the Code.
A senior member of Compliance will notify employees of any discrepancy between their personal activities and the rules outlined in this Code. Each violation and the circumstances surrounding each violation will be reviewed by a senior member of Compliance. Based on the review, a senior member of Compliance will determine whether the policies established in this Code have been violated, and whether any action should be taken. The CCO and/or the CO will determine appropriate sanctions (in accordance with Westfield's sanctions guidelines). Once the sanction has been approved, Compliance will notify the employee. Compliance has the discretion of reporting material Code matters to the Operations & Risk Management Committee and/or the Management Committee.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Appendix A: Glossary of Terms
Access Person is any Westfield employee or non-employee who meets at least one of the following conditions:
∙is an officer, director, or partner
∙has access to nonpublic information about client purchases or sales of securities
∙makes or participates in making investment recommendations to clients
∙has access to client investment recommendations that are non-public
∙has access to nonpublic information regarding the portfolio holdings of affiliated mutual funds
Beneficial Interest generally refers to the opportunity, directly or indirectly, to profit or share in any profit.
Business Day refers to every official Westfield working day of the week.
Client Account refers to any account over which Westfield has been granted authority to purchase and/or sell securities on the client's behalf.
Covered Account refers to any investment account over which an Access Person:
a.has direct or indirect beneficial interest; or
b.exercises investment control, meaning he or she actually provides input into or makes the security buy and/or sell decisions for the account. The account does not need to be in an Access Person's name; if an
Access Person has either joint or sole investment control over an account, it may be considered a Covered Account.
Covered Security refers to any security or fund that does not fall under one of the following exceptions:
∙Direct obligations of the Government of the United States (e.g., treasury bills, treasury bonds, U.S. savings bonds);
∙Bankers' acceptances, bank certificates of deposits, commercial paper, and high-quality short term debt instruments, including repurchase agreements;
∙Shares issued by money market funds;
∙Shares issued by open-end mutual funds that are not sub-advised or advised by Westfield;
∙Shares issued by unit investment trusts ("UITs") that are invested exclusively in one or more open-end mutual funds, none of which are sub-advised or advised by Westfield.
Employee means all Westfield personnel who are not hired on a temporary or contract basis.
Family member refers to a spouse, children, step-children, grandchildren, parents, step-parents, grandparents, domestic partners, siblings, parents-in-law, children-in-law, as well as adoptive relationships sharing the same household.
Investment Person means any Access Person who makes or participates in making investment recommendations for client accounts.
Reportable Fund means any pooled fund, regardless of whether it is offered publicly or privately, for which Westfield serves as adviser or sub-adviser. This includes Westfield limited partnerships.
Short Selling means selling a security that is not owned in the account.
Westfield Capital Management Company, L.P. Date Approved: 08/16/2019
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Appendix B: Sanctions Guidelines
Sanctions can be more or less than what is indicated in the table below. Sanctions such as disgorgement of profits (gross of any taxes or transaction costs) and reversal of trades may be considered in addition to or instead of the sanctions indicated in the table below, In recommending sanctions, Compliance will:
∙Consider an employee's role and responsibilities, past trading history, facts and circumstances around the violation and other applicable factors
∙Impose the highest of all applicable sanctions, if a violation falls within more than one category or if multiple violations occur on the same day
∙Review violations not listed in the table on a case-by-case basis
∙Consult with the Management Committee or Operations & Risk Management Committee members, if needed
Violation |
Management and Investment Committee, |
All Other Employees |
|
Research Analysts, Traders, Officers |
|
Late Reporting or |
First Offense: $500 |
First Offense: $100 |
Certification |
|
|
|
Second Offense: $750 and suspension of personal |
Second Offense: $200 and suspension of personal |
All listed fines are per day |
securities transaction rights (up to 6 months) |
securities transaction rights (up to 3 months) |
after due date and per report |
|
|
or certification |
Subsequent Offense: $1,500 and suspension of |
Subsequent Offense: $300 and suspension of |
|
personal securities transaction rights (up to 12 |
personal securities transaction rights (up to 6 |
|
months) |
months) |
|
|
|
Failure to Preclear |
First Offense: $2,000 per transaction and |
First Offense: $500 per transaction |
(includes trading more shares |
suspension of personal securities transaction rights |
|
then were precleared) |
for 30 days |
Second Offense: $1,000 per transaction and |
|
|
suspension of personal securities transaction |
|
Second Offense: $5,000 per transaction and |
rights for 30 days |
|
suspension of personal securities transaction rights |
|
|
for 3 months |
Subsequent Offense: $2,500 per transaction and |
|
|
suspension of personal securities transaction |
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|
Subsequent Offense: $10,000 per transaction and |
rights for 6 months |
|
suspension of personal securities transaction rights |
|
|
for 12 months |
|
Market Timing |
Termination of employment and civil or criminal |
Termination of employment and civil or criminal |
|
referral |
referral |
Failure to Make Accurate or |
Monetary fines starting at $5,000; suspension of |
Monetary fines starting at $1,000; suspension of |
Complete Reports |
personal securities transaction rights; possible |
personal securities transaction rights; possible |
|
termination of employment |
termination of employment |
Front Running |
$2,500 per transaction; temporary or permanent |
$2,500 per transaction; temporary or permanent |
|
suspension of personal securities transaction rights; |
suspension of personal securities transaction |
|
possible termination of employment |
rights; possible termination of employment |
30-day Holding Period |
First Offense: 2,000 per transaction |
First Offense: $500 per transaction |
|
Second Offense: $5,000 per transaction; |
Second Offense: $1,000 per transaction; |
|
suspension of personal transaction rights (up to 6 |
suspension of personal transaction rights (up to 6 |
|
months) |
months) |
|
Subsequent Offense: $7,500 per transaction; |
Subsequent Offense: $2,500 per transaction; |
|
suspension of personal securities transaction rights |
suspension of personal securities transaction |
|
(up to 12 months) |
rights (up to 12 months) |
Westfield Capital Management Company, L.P. Date Approved: 08/22/2018
COLUMBIA FUNDS SERIES TRUST
COLUMBIA FUNDS SERIES TRUST II
COLUMBIA FUNDS VARIABLE SERIES TRUST II
COLUMBIA SELIGMAN PREMIUM TECHNOLOGY GROWTH FUND, INC.
TRI-CONTINENTAL CORPORATION
(each a "Registrant")
POWER OF ATTORNEY
The undersigned does hereby constitute and appoint Michael G. Clarke, Marybeth Pilat, Joseph D'Alessandro, Paul B. Goucher, Ryan C. Larrenaga, Christopher O. Petersen, Michael E. DeFao and Megan E. Garcy, each individually, his true and lawful attorney-in-fact and agent (each an "Attorney-in-Fact") with power of substitution or resubstitution, in any and all capacities, including without limitation in the undersigned's capacity as Treasurer, Chief Accounting Officer (Principal Accounting Officer), and Principal Financial Officer of each Registrant, in the furtherance of the business and affairs of each Registrant: (i) to execute any and all instruments which said Attorney-in-Fact may deem necessary or advisable or which may be required to comply with the Securities Act of 1933, the Investment Company Act of 1940, the Securities Exchange Act of 1934 (together the "Acts") and any other applicable federal securities laws, or rules, regulations or requirements of the U.S. Securities and Exchange Commission ("SEC") in respect thereof, in connection with the filing and effectiveness of each Registrant's Registration Statement regarding the registration of each Registrant or its shares of beneficial interest, and any and all amendments thereto, including without limitation any reports, forms or other filings required by the Acts or any other applicable federal securities laws, or rules, regulations or requirements of the SEC; and (ii) to execute any and all federal, state or foreign regulatory or other required filings, including all applications with regulatory authorities, state charter or organizational documents and any amendments or supplements thereto, to be executed by, on behalf of, or for the benefit of, each Registrant. The undersigned hereby grants to each Attorney-in-Fact full power and authority to do and perform each and every act and thing contemplated above, as fully and to all intents and purposes as the undersigned might or could do in person, and hereby ratifies and confirms all that said Attorneys-in- Fact, individually or collectively, may lawfully do or cause to be done by virtue hereof.
This Power of Attorney shall not be revoked by any subsequent power of attorney I may execute unless such subsequent power of attorney specifically refers to this Power of Attorney or specifically states that the instrument is intended to revoke all prior general powers of attorney or all prior powers of attorney (and unless otherwise required by a provision of law that cannot be waived). This Power of Attorney shall terminate automatically with respect to a Registrant if the undersigned ceases to hold the above-referenced office(s) of the Registrant.
Dated: January 3, 2020
/s/ Joseph Beranek
Joseph Beranek