Definition of Personal Securities Transaction(s)


Personal Securities Transaction(s) means transactions in Securities for the account(s) in the names of Trust Personnel, or for accounts in which Trust Personnel have Beneficial Ownership.


Personal Securities Transaction(s) means any transaction in a Security pursuant to which an Access Person would have a Beneficial Ownership interest with the exception of obligations of the U.S. Government, bankers’ acceptances, bank certificates of deposit, money market fund shares, commercial paper, high quality short-term debt instruments and registered open and closed-end investment companies, none of which are funds advised or subadvised by the Firm.

Personal Securities Transaction(s) means any transaction in which an Access Person or his or her immediate family (as described herein) acquires or disposes of a Security in which the Access Person has or gains a direct or indirect Beneficial Ownership interest.

Examples of Personal Securities Transaction(s) in a sentence

Section IV — Reporting RequirementsReporting of Personal Securities Transactions Rule 1: Broker Confirmations and StatementsEach Putnam employee shall ensure that copies of all confirmations for securities transactions for personal brokerage accounts, and brokerage account statements are sent to the Legal and Compliance Department Code of Ethics Administrator.
Accordingly, you must comply with the policies and procedures set forth in this Code under the heading Personal Securities Transactions.
SECTION V -- Reporting RequirementsReporting of Personal Securities Transactions Rule 1: Broker Confirmations and StatementsEach Putnam employee shall ensure that copies of all confirmations for securities transactions for personal brokerage accounts, and brokerage account statements are sent to the Putnam Compliance Department Code of Ethics Administrator.
SECTION II -- Additional Special Rules for Personal Securities Transactions of Access Persons and Certain Investment ProfessionalsAccess Persons include all investment professionals and other employees as defined on page vii.
Although all Personal Securities Transactions by Access Persons must be conducted in a manner consistent with this Code, the Code itself is based on the premise that Access Persons owe a fiduciary duty to the Funds, and should avoid any activity that creates an actual, potential, or apparent conflict of interest.



More definitions of Personal Securities Transaction(s)

Personal Securities Transaction(s) means transactions in Securities (i) for your own account, including IRAs, or (ii) for an account in which you have indirect beneficial ownership, unless you have no direct or indirect influence or control over the account. Accounts involving family (including husband, wife, minor children or other dependent relatives), or accounts in which you have a beneficial interest (such as a trust of which you are an income or principal beneficiary) are included within the meaning of “indirect beneficial interest.”


Personal Securities Transaction(s) means transactions in Securities for the account(s) in the names of Access Persons, or for accounts in which the Access Persons have Beneficial Ownership.

Personal Securities Transaction(s) means transactions in securities 1) for your own accounts, including IRAs, or 2) for an account in which you have indirect beneficial ownership, unless you have no direct or indirect influence or control over the account. Accounts involving family members (including husband, wife, minor children or other dependent relatives), or accounts in which you have a beneficial interest (such as a trust of which you are an income or principal beneficiary) are included within the meaning of “indirect beneficial interest.” L. “Purchase or sale of a security” includes, among other things, the writing of an option to purchase or sell a security, the conversion of a convertible security, and the exercise of a warrant for the purchase of a security. M. “Review Officer” shall mean the officer or employee of ASA designated from time to time by ASA to pre-clear access person trades and to receive and review reports of purchases and sales by access persons. The term “Alternate Review Officer” shall mean the officer or employee of ASA designated from time to time by ASA to pre-clear Review Officer trades and to receive and review reports of purchases and sales by the Review Officer, and who shall act in all respects in the manner prescribed herein for the Review Officer. N. “Security” means any stock, bond, future, investment contract or any other instrument that is considered a “security” under the Advisers Act. The term “security” is very broad and includes items you might not ordinarily think of as securities, such as: 1) options on securities, on indexes, and on currencies, 2) all kinds of limited partnerships, 3) foreign unit trusts and foreign mutual funds, and 4) private investment funds, hedge funds, and investment clubs and ETF’s.

Personal Securities Transaction(s) means transactions in Securities for the account(s) in the names of Iridian Persons, or for accounts in which Iridian Persons have Beneficial Ownership.

Personal Securities Transaction(s) means: (A) transactions for a Director’s or Employee’s own account,

Personal Securities Transaction(s) means any transaction in a Security pursuant to which an Access Person would have a Beneficial Ownership interest

Personal Securities Transaction(s) Means an Access Person’s purchases or sales of Securities, including investments in an Initial Public Offering (“IPO”) or private placement. For purposes of this Code, the term “Personal Securities Transactions” includes transactions for accounts in which the Access Person has Beneficial Ownership. Section 2: General Fiduciary Principles The Code is designed to ensure that our conduct is at all times consistent with our fiduciary obligations to our clients, and with industry and regulatory standards for investment manager. The fundamental principles underlying NAMS’ Code are as follows: