Non-Access Person definition

Non-Access Person means and include:
Non-Access Person means and include: QS personnel who are not above, who do not have access to client trading activity or recommendations made in relation to any client account or as further determined by Compliance.
Non-Access Person means any Supervised Person of the Company that is NOT an Access Person. Because you do not receive non-public information about Advisory Client portfolios, you are subject only to the Standards of Business Conduct, Excessive Trading (in mutual fund shares); Closed-End Fund Pre-Clearance Restrictions; Blackout Periods-Allianz Shares, the Whistleblower Policy, Gifts and Entertainment, Political and Charitable Contributions, IPOs and Private Placements, Outside Business Activities, Service as a Director of a Public Company, and the Insider Trading Policy and Procedures of this Code. Certain operating entities may decide to classify all of its employees in one category, regardless of individual job duties and responsibilities. Your category may be subject to change if your position within your Company changes or if you have been transferred to another Company. If you have any questions about your classification, please contact your Chief Compliance Officer. Notwithstanding the foregoing, any trustee of NAIF who is not an Employee of Nicholas-Applegate Capital Management LLC (NACM) and any employee of NAIF’s administrator is deemed not to be an Access Person under the Code and is subject only to the Gifts and Entertainment (but not reporting requirements) and Insider Trading Policy and Procedures of the Code. However, any trustee of NAIF who is not an employee of NACM is subject to quarterly reporting if he or she knew or should have known that, during the 15-day period immediately before or after the trustee’s transaction in a Security as defined in this Code (except for Exempt Securities), a series of NAIF would purchase or sell such Security. Generally, trustees of NAIF will not have non-public information about the purchase and sale of securities for NAIF portfolios, or participate in making recommendations about such transactions. If a trustee obtains such information, he or she should contact the Chief Compliance Officer of NAIF for information about the steps the trustee should take to comply with the Code. REPORTABLE ACCOUNTS The following types of brokerage or trading accounts (“Accounts”) are required to be reported by Access Persons.

Examples of Non-Access Person in a sentence

  • Non-Access Persons: If you are an employee or temporary employee of Franklin Templeton Investments AND you do not fit into any of the above categories, you are a Non-Access Person.


More Definitions of Non-Access Person

Non-Access Person means any employee of the Company that is NOT an Access Person.
Non-Access Person means any director, officer, or employee of an ADAM Adviser that does NOT, in connection with their regular duties, makes, participates in, or has access to information regarding the purchase or sale of Covered Securities by the Advisory Clients of an ADAM Adviser. It also includes individuals who are not deemed an "interested person" of a Fund within the meaning of Section 2(a)(19) of the Investment Company Act of 1940, i.e. outside Fund Trustees.
Non-Access Person means any employee of the Adviser, the Administrator, the Funds, or any other company in a Control relationship to the Adviser or the Funds, which employee is not an “Access Person.”
Non-Access Person means any Supervised Person who does not meet either the definition of Access or Investment Person. Note: Any director, officer or employee of an investment adviser, who would be deemed an Access Person under this Code, who is subject to a code of ethics other than this Code that meets the requirements of Rule 204-2 under the Investment Firms Act of 1940 (the “IAA”), Sections 204A, 204A-1, and 206 of the Firms Act, and Rule 17j-1 under The Investment Company Act of 1940 (the “ICA”) shall be exempt from this Code.
Non-Access Person means any Supervised Person of the Company that is NOT an Access Person. Because you do not receive non-public information about Advisory Client portfolios, you are subject only to the Standards of Business Conduct, Excessive Trading (in mutual fund shares); Closed-End Fund Pre-Clearance Restrictions; Blackout Periods-Allianz Shares, the Whistleblower Policy, Gifts and Entertainment, Political and Charitable Contributions, IPOs and Private Placements, Outside Business Activities, Service as a Director of a Public Company, and the Insider Trading Policy and Procedures of this Code.
Non-Access Person means any employee or contractor of FI and its subsidiaries not falling within the above definition. Any questions about a person’s status should be directed to Chief Compliance Officer.