Common use of SUBADVISER CODE OF ETHICS Clause in Contracts

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating of the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will shall provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will shall provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) calendar days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president senior officer of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics6 14.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president a managing director or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to 6 the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics. 6 14.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, Act and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics. 6 14.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent its Access Persons from violating the Subadviser's code of ethics. The Subadviser will provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.to

SUBADVISER CODE OF ETHICS. The Subadviser certifies that the Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act, and that the Subadviser has instituted procedures reasonably necessary to prevent Access Persons from violating the Subadviser's code of ethics. The Subadviser will shall provide the Adviser and the Fund with a copy of that code, together with evidence of the code's adoption. Within twenty (20) days of the end of each calendar quarter during which this Agreement remains in effect, the president or a vice president of the Subadviser shall certify to the Adviser or the Fund that the Subadviser has complied with the requirements of Rule 17j-1 during the previous quarter and that there have been no violations of the Subadviser's code of ethics or, if a violation has occurred, that appropriate action has been taken in response to the violation; provided, that, no less frequently than annually, the appropriate officer of the Subadviser shall furnish a written report to the Adviser that complies with the requirements of Rule 17j-1 with respect to these reports regarding issues, material violations, and any related sanctions in connection with the administration of the code of ethics, or as otherwise required pursuant to Rule 17j-1. Upon written request of the Adviser or the Fund, the Subadviser shall permit representatives of the Adviser or the Fund to examine the reports (or summaries of the reports) required to be made to the Subadviser by Rule 17j-1(d)(1) and other records evidencing enforcement of the code of ethics.