CODE OF ETHICS
(Sarbanes-Oxley Act of 2002,
Section 406)
PRINCIPAL EXECUTIVE OFFICER
PRINCIPAL FINANCIAL OFFICER
PRINCIPAL ACCOUNTING OFFICER
THRIVENT CASH MANAGEMENT TRUST
THRIVENT SERIES FUND, INC.
THRIVENT CHURCH LOAN AND INCOME
FUND
It is the policy of the Thrivent Mutual Funds,
Thrivent Cash Management Trust, Thrivent Series Fund, Inc., Thrivent Core Funds
and Thrivent Church Loan and Income Fund (collectively, the "Funds")
that the President, as chief executive officer, and the Treasurer, as chief
financial officer and chief accounting officer (or persons performing similar
functions), of each Fund adhere to and advocate the following principles
governing their professional and ethical conduct in the fulfillment of their
responsibilities:
Act with honesty and integrity,
and ethically handle actual or apparent conflicts between his or her personal,
private interests and the interests of the Funds, including receiving improper
personal benefits as a result of his or her position.
Take such actions as are necessary
as to ensure that periodic reports filed with the Securities and Exchange
Commission and other public communications contain information which provides
full, fair, accurate, timely and understandable disclosure. Such actions shall
include adoption and maintenance of adequate disclosure controls and
procedures.
Comply with laws of federal,
state, and local governments applicable to the Funds, and the rules and
regulations of private and public regulatory agencies having jurisdiction over
the Funds.
Act in good faith, responsibly,
with due care and diligence, without misrepresenting or omitting material facts
or allowing independent judgment to be compromised.
Respect the confidentiality of
information acquired in the course of the performance of his or her
responsibilities except when authorized or otherwise legally obligated to
disclose such information. Do not use confidential information acquired in the
course of the performance of his or her responsibilities for personal
advantage.
Proactively promote ethical
behavior among subordinates and peers.
Use Fund assets and resources
employed or entrusted in a responsible manner.
Do not use Fund information,
assets, opportunities or one's position with the Funds for personal gain. Do
not compete directly or indirectly with the Funds.
Promptly report any violation of
this Code to the Chief Compliance Officer.
Comply in all respects with (a)
the Funds' Code of Ethics; (b) Thrivent Financial for Lutheran's Code of Conduct,
and (c) Thrivent Financial for Lutherans’ and Thrivent Asset Management, LLC’s Policy
on Insider Trading.
Acknowledge and certify compliance
with the foregoing annually and file a copy of such certification with the
Audit Committee of each Fund's Board of Directors/Trustees (“Fund Board”).
II. ADMINISTRATION
OF CODE
A. Chief Compliance Officer.
The Independent Directors of each Fund Board shall appoint a Chief
Compliance Officer, who shall have overall responsibility for ensuring this
Code is adhered to. In such capacity, the Chief Compliance Officer shall
report to each Fund Board's Audit Committee. The Chief Compliance Officer
shall be a person who has sufficient status within Thrivent Financial for
Lutherans to engender respect for the Code and the authority adequately to deal
with the persons subject to the Code regardless of their stature in the
company.
B. Amendments
Any material amendment to this Code shall be disclosed in
accordance with the requirements of Rule 30b2-1(a) under the Investment Company
Act of 1940, as amended (the "1940 Act"), and form N-CSR. Form N-CSR
does not require disclosure of technical, administrative or other
non-substantive amendments.
A waiver of
a provision of this Code must be requested whenever there is a reasonable
likelihood that a contemplated action will violate the Code. Requests for
waivers must be in writing and submitted to the Chief Compliance Officer, who
shall make a recommendation to the Audit Committee for final determination.
Any waiver or implicit waiver shall be disclosed in accordance with the
requirements of Rule 30b2-1(a) under the 1940 Act and Form N-CSR.
As used
herein, "waiver" means any approval by the Audit Committee of a
material departure from a provision of this Code. "Implicit waiver"
means failure by the Chief Compliance Officer or the Audit Committee to take
action within a reasonable period of time regarding a material departure from a
provision of the Code that has been made known to an executive officer (as
defined by Rule 3b-7 under the Securities Exchange Act of 1934, as amended) of
the Funds.
Upon learning of a
violation or potential violation of this Code, the Chief Compliance Officer
shall prepare a written report to Audit Committee providing full details and
recommendations for further action.
The Audit
Committee will, in consultation with the Chief Compliance Officer and/or such
legal counsel as the Audit Committee deems appropriate, make the final
determination of whether a violation has occurred and the action, if any, to be
taken in response thereto. The Audit Committee may take into account the
qualitative and quantitative materiality of the violation from the perspective
of either the determent to the Fund or the benefit to the violating officer,
the policy behind the provision violated and such other facts and circumstances
as it deems advisable under all of the facts and circumstances.
Any
material violation shall be reported in accordance with the requirements of
Rule 30b2-1 of the 1940 Act and Form N-CSR.
A copy of this Code of
Ethics shall be filed as an exhibit to each Fund's annual report on Form N-CSR.
The Chief
Compliance Officer or Chief Legal Officer shall retain copies of all records
required by Form N-CSR and/or rules and regulations promulgated under the 1940
Act.