Access Persons Sample Clauses

Access Persons o may not purchase or sell, directly or indirectly, any Security within 24 hours before or after the time that the same Security, (including any equity-related security of the same issuer such as preferred stock, options, warrants, and convertible bonds) is being purchased or sold by any Investment Vehicle for which SEI acts as advisor, distributor and/or administrator. o may not acquire Securities as part of an Initial Public Offering("IPO") without obtaining the written approval of the designated Compliance Officer at Mutual Fund Services before directly or indirectly acquiring a beneficial ownership in such securities. o may not acquire a beneficial ownership interest in Securities issued in a private placement transaction without obtaining prior written approval from the designated Compliance Officer at Mutual Fund Services. o may not receive any gift of more than de minimus value (currently $100.00 per year) from any person or entity that does business with or on behalf of any Investment Vehicle.