CODE OF ETHICS

FOR

SENIOR OFFICERS

Policy

This Code of Ethics for Senior Officers (this “Code”) sets forth the policies, practices and values expected to be exhibited by Senior Officers of the Pioneer Funds (collectively, the “Funds” and each, a “Fund”). This Code does not apply generally to officers and employees of service providers to the Funds, including Amundi Asset Management US, Inc., and Amundi Distributor US, Inc. (collectively, “Amundi US”), unless such officers and employees are also Senior Officers.

The term “Senior Officers” shall mean the principal executive officer, principal financial officer, principal accounting officer and controller of the Funds, although one person may occupy more than one such office. Each Senior Officer is identified by title in Exhibit A to this Code.

The Chief Compliance Officer (“CCO”) of the Pioneer Funds is primarily responsible for implementing and monitoring compliance with this Code, subject to the overall supervision of the Board of Trustees of the Funds (the “Board”). The CCO has the authority to interpret this Code and its applicability to particular situations. Any questions about this Code should be directed to the CCO or his or her designee.

Purpose

The purposes of this Code are to:

Promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

Promote full, fair, accurate, timely and understandable disclosure in reports and documents that the Fund files with, or submits to, the Securities and Exchange Commission (“SEC”) and in other public communications made by the Fund;


	1	Last revised January 2021

Promote compliance with applicable laws and governmental rules and regulations;

Promote the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

Establish accountability for adherence to the Code.

Each Senior Officer should adhere to a high standard of business ethics and should be sensitive to situations that may give rise to actual as well as apparent conflicts of interest.

Responsibilities of Senior Officers

Conflicts of Interest

A “conflict of interest” occurs when a Senior Officer’s private interests interfere in any way – or even appear to interfere – with the interests of or his/her service to a Fund. A conflict can arise when a Senior Officer takes actions or has interests that may make it difficult to perform his or her Fund work objectively and effectively. Conflicts of interest also arise when a Senior Officer or a member of his/her family receives improper personal benefits as a result of the Senior Officer’s position with the Fund.

Certain conflicts of interest arise out of the relationships between Senior Officers and the Fund and already are subject to conflict of interest provisions in the Investment Company Act of 1940, as amended (the “ICA”), and the Investment Advisers Act of 1940, as amended (the “IAA”). For example, Senior Officers may not individually engage in certain transactions (such as the purchase or sale of securities or other property) with the Funds because of their status as “affiliated persons” of the Funds. The Fund's and Amundi US’ compliance programs and procedures are designed to prevent, or identify and correct, violations of these provisions. This Code does not, and is not intended to, repeat or replace such policies and procedures, and such conflicts fall outside of the parameters of this Code.

Although typically not presenting an opportunity for improper personal benefit, conflicts arise as a result of the contractual relationship between the Fund and Amundi US because the Senior Officers are officers or employees of both. As a result, this Code recognizes that Senior Officers will, in the normal course of their duties (whether formally for a Fund or for Amundi US, or for both), be involved in establishing policies and implementing decisions that will have different effects on Amundi US and the Fund. The participation of Senior Officers in such activities is inherent in the contractual relationship between a Fund and Amundi US and is consistent with the performance by the Senior Officers of their duties as officers of the Fund and, if addressed in conformity with the provisions of the ICA and the IAA, will be deemed to have been handled ethically. In addition, it is recognized by the Board that Senior Officers may also be officers of investment companies other than the Pioneer Funds.

Other conflicts of interest are covered by this Code, even if such conflicts of interest are not subject to provisions of the ICA or the IAA. In reading the following examples of conflicts of interest under this Code, Senior Officers should keep in mind that such a list cannot ever be exhaustive or cover every possible scenario. It follows that the overarching principle is that the personal interest of a Senior Officer should not be placed improperly before the interest of a Fund.


	2	Last revised January 2021

Each Senior Officer must:

Not use his or her personal influence or personal relationships improperly to influence investment decisions or financial reporting by a Fund whereby the Senior Officer would benefit personally to the detriment of the Fund;

Not cause a Fund to take action, or fail to take action, for the individual personal benefit of the Senior Officer rather than the benefit of the Fund; and

Report at least annually any affiliations or other relationships that give rise to conflicts of interest.

Any material conflict of interest situation should be approved by the CCO, his or her designee or the Board. Examples of these include:

Service as a director on the board of any public or private company;

The receipt of any gift with a value in excess of an amount established from time to time by Amundi US’ Business Gift and Entertainment Policy from any single non-relative person or entity. Customary business lunches, dinners and entertainment at which both the Senior Officer and the giver are present, and promotional items of insignificant value are exempt from this prohibition;

The receipt of any entertainment from any company with which a Fund has current or prospective business dealings unless such entertainment is business-related, reasonable in cost, appropriate as to time and place, and not so frequent as to raise any question of impropriety;

Any ownership interest in, or any consulting or employment relationship with, any of a Fund’s service providers other than its investment adviser, principal underwriter, administrator or any affiliated person thereof; and

A direct or indirect financial interest in commissions, transaction charges or spreads paid by a Fund for effecting portfolio transactions or for selling or redeeming shares other than an interest arising from the Senior Officer’s employment, such as compensation or equity ownership.

Corporate Opportunities

Senior Officers may not (a) take for themselves personally opportunities that are discovered through the use of a Fund’s property, information or position; (b) use a Fund’s property, information, or position for personal gain; or (c) compete with a Fund. Senior Officers owe a duty to the Funds to advance their legitimate interests when the opportunity to do so arises.


	3	Last revised January 2021

Confidentiality

Senior Officers should maintain the confidentiality of information entrusted to them by the Funds, except when disclosure is authorized or legally mandated. Confidential information includes all non-public information that might be of use to competitors, or harmful to the Funds, if disclosed.

Fair dealing with Fund shareholders, suppliers, and competitors

Senior Officers should endeavor to deal fairly with the Funds’ shareholders, suppliers, and competitors. Senior Officers should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Senior Officers should not knowingly misrepresent or cause others to misrepresent facts about a Fund to others, whether within or outside the Fund, including to the Board, the Funds’ auditors or to governmental regulators and self-regulatory organizations.

Compliance with Law

Each Senior Officer must not knowingly violate any law, rule and regulation applicable to his or her activities as an officer of the Funds. In addition, Senior Officers are responsible for understanding and promoting compliance with the laws, rules and regulations applicable to his or her particular position and by persons under the Senior Officer’s supervision. Senior Officers should endeavor to comply not only with the letter of the law, but also with the spirit of the law.

Disclosure

Each Senior Officer should familiarize himself or herself with the disclosure requirements generally applicable to the Funds. Each Senior Officer should, to the extent appropriate within his or her area of responsibility, consult with other officers of the Funds and Amundi US with the goal of promoting full, fair, accurate, timely and understandable disclosure in the reports and documents a Fund files with, or submits to, the SEC and in other public communications made by the Funds.

Initial and Annual Certifications

Upon becoming a Senior Officer the Senior Officer is required to certify that he or she has received, read, and understands this Code. On an annual basis, each Senior Officer must certify that he or she has complied with all of the applicable requirements of this Code.

Administration and Enforcement of the Code

Report of Violations

Amundi US relies on each Senior Officer to report promptly if he or she knows of any conduct by a Senior Officer in violation of this Code. All violations or suspected violations of this Code must be reported to the CCO or a member of Amundi US’ Legal and Compliance Department. Failure to do so is itself a violation of this Code.


	4	Last revised January 2021

Investigation of Violations

Upon notification of a violation or suspected violation, the CCO or other members of Amundi US’ Compliance Department will take all appropriate action to investigate the potential violation reported. If, after such investigation, the CCO believes that no violation has occurred, the CCO and Compliance Department is not required to take no further action. Any matter the CCO believes is a violation will be reported to the Independent Trustees. If the Independent Trustees concur that a violation has occurred, they will inform and make a recommendation to the full Board. The Board shall be responsible for determining appropriate action. The Funds, their officers and employees, will not retaliate against any Senior Officer for reports of potential violations that are made in good faith and without malicious intent.

The CCO or his or her designee is responsible for applying this Code to specific situations in which questions are presented under it and has the authority to interpret this Code in any particular situation. The CCO or his or her designee shall make inquiries regarding any potential conflict of interest.

Violations and Sanctions

Compliance with this Code is expected and violations of its provisions will be taken seriously and could result in disciplinary action. In response to violations of the Code, the Board may impose such sanctions as it deems appropriate within the scope of its authority over Senior Officers, including termination as an officer of the Funds.

Waivers from the Code

The Independent Trustees will consider any approval or waiver sought by any Senior Officer.

The Independent Trustees will be responsible for granting waivers, as appropriate. Any change to or waiver of this Code will, to the extent required, be disclosed as provided by SEC rules.

Other Policies and Procedures

This Code shall be the sole Code of Ethics adopted by the Funds for purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to registered investment companies thereunder. The Funds’ and Amundi US’ Codes of Ethics under Rule 17j-1 under the ICA and Rule 204A-1 of the IAA are separate requirements applying to the Senior Officers and others, and are not a part of this Code. To the extent any other policies and procedures of the Funds or Amundi US overlap or conflict with the provisions of the Code, they are superseded by this Code.

Scope of Responsibilities

A Senior Officer’s responsibilities under this Code are limited to Fund matters over which the Senior Officer has direct responsibility or control, matters in which the Senior Officer routinely participates, and matters with which the Senior Officer is otherwise involved. In addition, a Senior Officer is responsible for matters of which the Senior Officer has actual knowledge.


	5	Last revised January 2021

Amendments

This Code other than Exhibit A may not be amended except in a writing that is specifically approved or ratified by a majority vote of the Board, including a majority of the Independent Trustees.

Confidentiality

All reports and records prepared or maintained pursuant to this Code will be considered confidential and shall be maintained and protected accordingly. Except as otherwise required by law or this Code, such matters shall not be disclosed to anyone other than the Board and their counsel, or to Amundi US’ Legal and Compliance Department.

Internal Use

This Code is intended solely for the internal use by the Funds and does not constitute an admission, by or on behalf of any Fund, as to any fact, circumstance, or legal conclusion.


	6	Last revised January 2021

Exhibit A – Senior Officers of the Pioneer Funds (Effective as of August 14, 2008)

President (Principal Executive Officer)

Treasurer (Principal Financial Officer)

Code of Ethics for Senior Officers

Table of Contents
President’s Letter	2
Portfolio Management Discussion	4
Portfolio Summary	10
Prices and Distributions	11
Performance Update	12
Comparing Ongoing Fund Expenses	20
Schedule of Investments	22
Financial Statements	24
Notes to Financial Statements	32
Approval of Renewal of Investment Management Agreement	42
Trustees, Officers and Service Providers	47


Balanced/Flexible
Pioneer Multi-Asset Income Fund Class K	29.8%
Pioneer Flexible Opportunities Fund Class K	19.9
International Equities
Pioneer Global Equity Fund Class K	15.7%
Pioneer International Equity Fund Class Y	14.1


Fixed Income
Pioneer Multi-Asset Ultrashort Income
Fund Class K	9.9%
Pioneer Bond Fund Class K	2.7
Pioneer Strategic Income Fund Class K	2.0
Pioneer ILS Interval Fund	0.2
U.S. Equities
Pioneer Disciplined Value Fund Class Y	1.5%
Pioneer Core Equity Fund Class K	1.2
Pioneer Equity Income Fund Class K	1.0
Pioneer Fund Class K	1.0
Pioneer Fundamental Growth Fund Class K	1.0

Class	1/31/22	7/31/21
A	$12.71	$13.20
C	$11.52	$11.99
R	$12.62	$13.10
Y	$12.91	$13.42

	Net Investment	Short-Term	Long-Term
Class	Income	Capital Gains	Capital Gains
A	$0.4515	$0.0620	$0.2891
C	$0.3531	$0.0620	$0.2891
R	$0.4216	$0.0620	$0.2891
Y	$0.4884	$0.0620	$0.2891


Average Annual Total Returns
(As of January 31, 2022)
		Public			60% MSCI World NR
	Net Asset	Offering	Bloomberg		Index/40% Bloomberg
	Value	Price	US Aggregate	MSCI World	US Aggregate
Period	(NAV)	(POP)	Bond Index	NR Index	Bond Index
10 years	6.37%	5.74%	2.59%	11.54%	8.11%
5 years	7.29	6.03	3.08	13.25	9.38
1 year	12.50	6.06	-2.97	16.53	8.48


Share Class	A	C	R	Y
Beginning Account	$1,000.00	$1,000.00	$1,000.00	$1,000.00
Value on 8/1/21
Ending Account Value	$1,023.60	$1,019.40	$1,022.20	$1,024.40
(after expenses)
on 1/31/22
Expenses Paid	$2.24	$5.96	$3.42	$1.28
During Period*

			Change
			in Net
		Net	Unrealized	Capital
		Realized	Appreciation	Gain	Dividend
		Gain (Loss)	(Depreciation)	Distributions	Income
	AFFILIATED ISSUERS — 99.7%*
	MUTUAL FUNDS — 99.5% of Net Assets
1,197,884	Pioneer Bond Fund Class K	(495,867)	(56,943)	466,899	48,622	$ 11,403,853
238,717	Pioneer Core Equity Fund	1,870,695	(2,683,115)	1,114,394	43,864	5,392,606
	Class K
405,422	Pioneer Disciplined Value	(29,817)	(673,814)	820,775	62,466	6,531,354
	Fund Class Y
113,657	Pioneer Equity Income	1,415,689	(1,557,946)	497,252	63,297	4,520,158
	Fund Class K
6,323,383	Pioneer Flexible	251,120	(2,641,341)	542,050	947,583	87,705,320
	Opportunities Fund
	Class K
121,605	Pioneer Fund Class K	(198,278)	(626,738)	906,779	11,010	4,517,611
145,140	Pioneer Fundamental	266,636	(992,919)	752,326	6,001	4,352,734
	Growth Fund Class K
3,875,636	Pioneer Global Equity	668,041	(9,462,823)	10,997,183	1,619,179	68,831,298
	Fund Class K
2,485,115	Pioneer International	147,784	(6,292,723)	6,044,280	1,665,115	62,003,629
	Equity Fund Class Y
10,728,847	Pioneer Multi-Asset	(251,655)	2,193,829	—	4,420,749	130,891,938
	Income Fund Class K
4,506,431	Pioneer Multi-Asset	62,899	(218,321)	—	309,764	43,712,376
	Ultrashort Income Fund
	Class K
838,137	Pioneer Strategic Income	(79,402)	(290,816)	159,043	86,823	8,875,870
	Fund Class K
	TOTAL MUTUAL FUNDS
	(Cost $389,582,374)	$3,627,845	$(23,303,670)	$22,300,981	$9,284,473	$ 438,738,747
	CLOSED-END FUND — 0.2% of Net Assets
112,257	Pioneer ILS Interval Fund	(289,999)	(275,529)	—	225,443	$ 926,122
	TOTAL CLOSED-END FUND
	(Cost $945,923)	$ (289,999)	$ (275,529)	$ —	$ 225,443	$ 926,122
	TOTAL INVESTMENTS IN AFFILIATED ISSUERS — 99.7%
	(Cost $390,528,297)	$3,337,846	$(23,579,199)	$22,300,981	$9,509,916	$ 439,664,869

Shares		Value
	UNAFFILIATED ISSUERS — 0.3%
	SHORT TERM INVESTMENTS — 0.3% of Net Assets
	Open-End Fund — 0.3%
1,524,616	Dreyfus Government Cash Management, Institutional
	Shares, 0.03%(a)	$ 1,524,616
		$ 1,524,616
	TOTAL SHORT TERM INVESTMENTS
	(Cost $1,524,616)	$ 1,524,616
	TOTAL INVESTMENTS IN UNAFFILIATED
	ISSUERS — 0.3%
	(Cost $1,524,616)	$ 1,524,616
	OTHER ASSETS AND LIABILITIES — (0.0)%†	$ (103,792)
	NET ASSETS — 100.0%	$ 441,085,693

Aggregate gross unrealized appreciation for all investments in which
there is an excess of value over tax cost	$ 50,021,178
Aggregate gross unrealized depreciation for all investments in which
there is an excess of tax cost over value	(884,606)
Net unrealized appreciation	$ 49,136,572


	Level 1	Level 2	Level 3	Total
Open-End Fund	$ 1,524,616	$ —	$ —	$ 1,524,616
Affiliated Funds	438,738,747	926,122	—	439,664,869
Total Investments
in Securities	$440,263,363	$ 926,122	$ —	$441,189,485


ASSETS:
Investments in unaffiliated issuers, at value (cost $1,524,616)	$ 1,524,616
Investments in affiliated issuers, at value (cost $390,528,297)	439,664,869
Receivables —
Fund shares sold	358,930
Interest	153
Other assets	31,106
Total assets	$ 441,579,674
LIABILITIES:
Payables —
Fund shares repurchased	$ 356,542
Trustees’ fees	2,047
Professional fees	34,084
Transfer agent fees	64,646
Due to affiliates	19,767
Accrued expenses	16,895
Total liabilities	$ 493,981
NET ASSETS:
Paid-in capital	$ 375,188,150
Distributable earnings	65,897,543
Net assets	$ 441,085,693
NET ASSET VALUE PER SHARE:
No par value (unlimited number of shares authorized)
Class A (based on $386,602,162/30,425,628 shares)	$ 12.71
Class C (based on $50,154,423/4,352,948 shares)	$ 11.52
Class R (based on $1,620,621/128,412 shares)	$ 12.62
Class Y (based on $2,708,487/209,727 shares)	$ 12.91
MAXIMUM OFFERING PRICE PER SHARE:
Class A (based on $12.71 net asset value per share/100%-5.75%
maximum sales charge)	$ 13.49

INVESTMENT INCOME:
Dividend income from underlying affiliated funds	$ 9,509,916
Interest from unaffiliated issuers		372
Total Investment Income			$ 9,510,288
EXPENSES:
Administrative expenses	$ 104,532
Transfer agent fees
Class A		149,987
Class C		15,492
Class R		518
Class Y		2,105
Distribution fees
Class A		495,285
Class C		274,259
Class R		4,425
Shareowner communications expense		65,119
Custodian fees		4,549
Registration fees		29,149
Professional fees		29,523
Printing expense		7,160
Trustees’ fees		9,021
Miscellaneous		16,978
Total expenses			$ 1,208,102
Net investment income			$ 8,302,186
REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS:
Net realized gain (loss) on:
Investments in underlying affiliated funds	$ 3,337,846
Capital gain on distributions from underlying affiliated issuers		22,300,981	$25,638,827
Change in net unrealized appreciation (depreciation) on:
Investments in underlying affiliated funds	$(23,579,199)
Net realized and unrealized gain (loss) on investments			$ 2,059,628
Net increase in net assets resulting from operations			$10,361,814

	Six Months
	Ended	Year
	1/31/22	Ended
	(unaudited)	7/31/21
FROM OPERATIONS:
Net investment income (loss)	$ 8,302,186	$ 8,112,216
Net realized gain (loss) on investments	25,638,827	9,238,394
Change in net unrealized appreciation (depreciation)
on investments	(23,579,199)	74,920,163
Net increase in net assets resulting from operations	$ 10,361,814	$ 92,270,773
DISTRIBUTIONS TO SHAREOWNERS:
Class A ($0.80 and $0.33 per share, respectively)	$ (23,137,520)	$ (10,156,686)
Class C ($0.70 and $0.24 per share, respectively)	(2,977,945)	(1,258,078)
Class R ($0.77 and $0.33 per share, respectively)	(93,473)	(46,785)
Class Y ($0.84 and $0.36 per share, respectively)	(166,805)	(50,353)
Total distributions to shareowners	$ (26,375,743)	$ (11,511,902)
FROM FUND SHARE TRANSACTIONS:
Net proceeds from sales of shares	$ 16,990,002	$ 39,686,202
Reinvestment of distributions	26,111,222	11,400,298
Cost of shares repurchased	(44,335,815)	(69,589,068)
Net decrease in net assets resulting from Fund
share transactions	$ (1,234,591)	$ (18,502,568)
Net increase (decease) in net assets	$ (17,248,520)	$ 62,256,303
NET ASSETS:
Beginning of period	$ 458,334,213	$396,077,910
End of period	$ 441,085,693	$458,334,213

	2021
Distributions paid from:
Ordinary income	$ 9,730,229
Long-term capital gains	1,781,673
Total	$11,511,902


	2021
Distributable earnings/(losses):
Undistributed ordinary income	$ 5,666,926
Undistributed long-term capital gains	7,096,139
Net unrealized appreciation	69,148,407
Total	$81,911,472

Shareowner Communications:
Class A	$58,991
Class C	5,750
Class R	198
Class Y	180
Total	$65,119


						Change in
				Net		net unrealized
				realized		appreciation/
				gain/(loss)	Dividends	(depreciation)
				from	from	from	Shares
Name of	Value at			Investments	Investments	Investments	held at	Value
the Affiliated	July 31,			in Affiliated	in Affiliated	in Affiliated	January 31,	January 31,
Issuer	2021	Purchases	Sales	Issuers	Issuers	Issuers	2022	2022
Pioneer Bond
Fund Class K	$ 59,831	$25,027,862	$ (13,179,652)	$ (495,867)	$ 48,622	$ (56,943)	1,197,884	$ 11,403,853
Pioneer Core
Equity Fund
Class K	12,226,465	1,114,394	(7,179,697)	1,870,695	43,864	(2,683,115)	238,717	5,392,606
Pioneer Disciplined
Value Fund
Class Y	—	12,434,503	(5,261,984)	(29,817)	62,466	(673,814)	405,422	6,531,354
Pioneer Equity
Income Fund
Class K	11,714,577	1,207,648	(8,323,107)	1,415,689	63,297	(1,557,946)	113,657	4,520,158
Pioneer Flexible
Opportunities
Fund Class K	91,368,416	3,536,937	(5,757,395)	251,120	947,583	(2,641,341)	6,323,383	87,705,320
Pioneer Fund
Class K	4,835,560	3,091,868	(2,595,811)	(198,278)	11,010	(626,738)	121,605	4,517,611
Pioneer Fundamental
Growth Fund
Class K	4,995,271	1,096,089	(1,018,344)	266,636	6,001	(992,919)	145,140	4,352,734
Pioneer Global
Equity Fund
Class K	68,106,261	11,534,566	(3,633,926)	668,041	1,619,179	(9,462,823)	3,875,636	68,831,298
Pioneer ILS
Interval Fund	11,655,729	—	(10,389,522)	(289,999)	225,443	(275,529)	112,257	926,122
Pioneer International
Equity Fund
Class Y	61,088,085	6,044,281	(648,913)	147,784	1,665,115	(6,292,723)	2,485,115	62,003,629
Pioneer Multi-Asset
Income Fund
Class K	136,613,806	3,696,859	(15,781,650)	(251,655)	4,420,749	2,193,829	10,728,847	130,891,938
Pioneer Multi-Asset
Ultrashort Income
Fund Class K	49,862,157	15,833,618	(22,137,741)	62,899	309,764	(218,321)	4,506,431	43,712,376
Pioneer Strategic
Income Fund
Class K	2,362,368	8,862,148	(2,065,251)	(79,402)	86,823	(290,816)	838,137	8,875,870
Total	$454,888,526	$93,480,773	$ (97,972,993)	$3,337,846	$9,509,916	$(23,579,199)	31,092,231	$ 439,664,869

Call us for:
Account Information, including existing accounts,
new accounts, prospectuses, applications
and service forms	1-800-225-6292
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Our toll-free fax	1-800-225-4240

Our internet e-mail address	us.askamundi@amundi.com/us
(for general questions about Amundi only)

Visit our web site: www.amundi.com/us.

SECTION II - POLICY

SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION		SPECIFIC PRE-APPROVED SERVICE SUBCATEGORIES

I. AUDIT SERVICES	Services that are directly		o Accounting research assistance
	related to performing the		o SEC consultation, registration
	independent audit of the Funds		statements, and reporting
			o Tax accrual related matters
			o Implementation of new accounting standards
			o Compliance letters (e.g. rating agency letters)
			o Regulatory reviews and assistance
			regarding financial matters
			o Semi-annual reviews (if requested)
			o Comfort letters for closed end offerings
II. AUDIT-RELATED	Services which are not		o AICPA attest and agreed-upon procedures
SERVICES	prohibited under Rule		o Technology control assessments
	210.2-01(C)(4) (the “Rule”)		o Financial reporting control assessments
	and are related extensions of		o Enterprise security architecture
	the audit services support the		assessment
	audit, or use the knowledge/expertise
	gained from the audit procedures as a
	foundation to complete the project.
	In most cases, if the Audit-Related
	Services are not performed by the
	Audit firm, the scope of the Audit
	Services would likely increase.
	The Services are typically well-defined
	and governed by accounting
	professional standards (AICPA,
	SEC, etc.)

AUDIT COMMITTEE APPROVAL POLICY		AUDIT COMMITTEE REPORTING POLICY
o “One-time” pre-approval		o A summary of all such
for the audit period for all		services and related fees
pre-approved specific service		reported at each regularly
subcategories. Approval of the		scheduled Audit Committee
independent auditors as		meeting.
auditors for a Fund shall
constitute pre approval for
these services.

o “One-time” pre-approval		o A summary of all such
for the fund fiscal year within		services and related fees
a specified dollar limit		(including comparison to
for all pre-approved		specified dollar limits)
specific service subcategories		reported quarterly.

o Specific approval is
needed to exceed the
pre-approved dollar limit for
these services (see general
Audit Committee approval policy
below for details on obtaining
specific approvals)

o Specific approval is
needed to use the Fund’s
auditors for Audit-Related
Services not denoted as
“pre-approved”, or
to add a specific service
subcategory as “pre-approved”


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PRE-APPROVED SERVICE
		SUBCATEGORIES
III. TAX SERVICES	Services which are not	o Tax planning and support
	prohibited by the Rule,	o Tax controversy assistance
	if an officer of the Fund	o Tax compliance, tax returns, excise
	determines that using the	tax returns and support
	Fund’s auditor to provide	o Tax opinions
	these services creates
	significant synergy in
	the form of efficiency,
	minimized disruption, or
	the ability to maintain a
	desired level of
	confidentiality.


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PROHIBITED SERVICE
		SUBCATEGORIES
PROHIBITED SERVICES	Services which result	1. Bookkeeping or other services
	in the auditors losing	related to the accounting records or
	independence status	financial statements of the audit
	under the Rule.	client*
		2. Financial information systems design
		and implementation*
		3. Appraisal or valuation services,
		fairness* opinions, or
		contribution-in-kind reports
		4. Actuarial services (i.e., setting
		actuarial reserves versus actuarial
		audit work)*
		5. Internal audit outsourcing services*
		6. Management functions or human
		resources
		7. Broker or dealer, investment
		advisor, or investment banking services
		8. Legal services and expert services
		unrelated to the audit
		9. Any other service that the Public
		Company Accounting Oversight Board
		determines, by regulation, is
		impermissible


AUDIT COMMITTEE APPROVAL POLICY	AUDIT COMMITTEE REPORTING POLICY
o These services are not to be	o A summary of all
performed with the exception of the(*)	services and related
services that may be permitted	fees reported at each
if they would not be subject to audit	regularly scheduled
procedures at the audit client (as	Audit Committee meeting
defined in rule 2-01(f)(4)) level	will serve as continual
the firm providing the service.	confirmation that has
	not provided any
	restricted services.