THE SECURITIES ACT OF 1933 | ||||
Post-Effective Amendment No. 87 | x |
THE INVESTMENT COMPANY ACT OF 1940 | ||||
Amendment No. 88 | x |
(a) | Articles of Incorporation of Summit Mutual Funds, Inc., incorporated by reference to Registrant's initial filing on April 3, 1984. Articles of Amendment of Summit Mutual Funds, Inc., incorporated by reference to Registrant's Post-Effective Amendment No. 69, April 29, 2010, accession number 0000743773-10-000011. |
(b) | Amended and Re-stated By-laws of Calvert Variable Products, Inc., incorporated by reference to Registrant’s Post-Effective Amendment No. 81, April 29, 2015, accession number 0000743773-15-000022. |
(c) | Instruments Defining Rights of Security Holders (not applicable). |
(d)(1) | Investment Advisory Agreement with Calvert Investment Management, Inc., incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Addendum to Investment Advisory Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 74, April 27, 2012, accession number 0000743773-12-000004. Amendment to Investment Advisory Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. Schedule A and B to Investment Advisory Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. Addendum to the Investment Advisory Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 81, April 29, 2015, accession number 0000743773-15-000022. Addendum to the Investment Advisory Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 83, October 30, 2015, accession number 0000743773-15-000064. Addendum to the Investment Advisory Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 85, April 28, 2016, accession number 0000743773-16-000092. |
(d)(2) | Investment Subadvisory Agreement with Ameritas Investment Partners, Inc., incorporated by reference to Registrant’s Post-Effective Amendment No. 76, April 5, 2013, accession number 0000743773-13-000012. |
(d)(3) | Investment Subadvisory Agreement with World Asset Management, Inc., incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. |
(d)(4) | Investment Subadvisory Agreement with Milliman Financial Risk Management LLC, incorporated by reference to Registrant’s Post-Effective Amendment No. 76, April 5, 2013, accession number 0000743773-13-000012. |
(e) | Underwriting (Distribution) Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Amendment to Underwriting (Distribution) Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 74, April 27, 2012, accession number 0000743773-12-000004. Amendment to Underwriting Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. Amendment to Underwriting Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 83, October 30, 2015, accession number 0000743773-15-000064. |
(f) | Form of Directors' Deferred Compensation Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. |
(g) | Master Custodian Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Amended Appendix A to Master Custodian Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Amendment to the Master Custodian Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 76, April 5, 2013, accession number 0000743773-13-000012. |
(h)(1) | Master Transfer Agency and Service Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Amended Schedule A to Master Transfer Agency and Service Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Amendment to the Master Transfer Agency and Service Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 76, April 5, 2013, accession number 0000743773-13-000012. Amendment to Master Transfer Agency and Service Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 85, April 28, 2016, accession number 0000743773-16-000092. |
(h)(2) | Amended and Restated Servicing Agreement, incorporated by reference to Registrant's initial N-14 filing, dated December 17, 2012, accession number 0000743773-12-000029. Amendment to the Amended and Restated Servicing Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. |
(h)(3) | Administrative Services Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. Schedule A to Administrative Services Agreement, incorporated by reference to Registrant's Post-Effective Amendment No. 70, April 27, 2011, accession number 0000743773-11-000009. Amendment to Administrative Services Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 74, April 27, 2012, accession number 0000743773-12-000004. Amendment to the Administrative Services Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. Amendment to Administrative Services Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 85, April 28, 2016, accession number 0000743773-16-000092. |
(h)(4) | Administration Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 85, April 28, 2016, accession number 0000743773-16-000092. Amendment to Administration Agreement, incorporated by reference to Registrant’s Post-Effective Amendment No. 85, April 28, 2016, accession number 0000743773-16-000092. |
(i) | Opinion and Consent of Counsel (not applicable). |
(j) | Consent of Independent Auditors to use of Report (not applicable). |
(k) | Omitted Financial Statements (not applicable). |
(l) | Letter regarding initial capital, incorporated by reference to Registrant's Pre-Effective Amendment No. 1, filed on July 2, 1984. |
(m) | Amended and Restated 12b-1 Distribution and Shareholder Service Plan, incorporated by reference to Registrant’s Post-Effective Amendment No. 76, April 5, 2013, accession number 0000743773-13-000012. Revised Schedule A, Amended and Restated 12b-1 Distribution and Shareholder Service Plan, incorporated by reference to Registrant’s Post-Effective Amendment No. 83, October 30, 2015, accession number 0000743773-15-000064. |
(n) | Amended and Restated Rule 18f-3 Multiple Class Plan, incorporated by reference to Registrant’s Post-Effective Amendment No. 80, April 29, 2014, accession number 0000743773-14-000026. Amendment to Rule 18f-3 Multiple Class Plan, incorporated by reference to Registrant’s Post-Effective Amendment No. 83, October 30, 2015, accession number 0000743773-15-000064. |
(o) | Not applicable. |
(p)(1) | Amended Code of Ethics for Calvert Funds et al., filed herewith. |
(p)(2) | Code of Ethics for Ameritas Investment Partners, Inc., incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. |
(p)(3) | Code of Ethics for World Asset Management, Inc., incorporated by reference to Registrant's Post-Effective Amendment No. 65, January 30, 2009, accession number 0000743773-09-000003. |
(p)(4) | Code of Ethics for Milliman Financial Risk Management LLC, incorporated by reference to Registrant’s Post-Effective Amendment No. 75, February 5, 2013, accession number 0000743773-13-000005. |
(q) | Power of Attorney forms, incorporated by reference to Registrant’s Post-Effective Amendment No. 85, April 28, 2016, accession number 0000743773-16-000092. |
Name | Name of Company, Principal Business and Address | Capacity |
John H. Streur | ||
Calvert Management Series Calvert Social Investment Fund The Calvert Fund Calvert Responsible Index Series, Inc. Calvert Impact Fund, Inc. Calvert Variable Series, Inc. Calvert World Values Fund, Inc. Calvert SAGE Fund Calvert Variable Products, Inc. Investment Companies 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer, Trustee/ Director | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Vicki L. Benjamin | ||
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Management Series Calvert Social Investment Fund The Calvert Fund Calvert Responsible Index Series, Inc. Calvert Impact Fund, Inc. Calvert Variable Series, Inc. Calvert World Values Fund, Inc. Calvert SAGE Fund Calvert Variable Products, Inc. Investment Companies 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Andrew K. Niebler |
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Management Series Calvert Social Investment Fund The Calvert Fund Calvert Responsible Index Series, Inc. Calvert Impact Fund, Inc. Calvert Variable Series, Inc. Calvert World Values Fund, Inc. Calvert SAGE Fund Calvert Variable Products, Inc. Investment Companies 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Robert D. Benson | ||
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Management Series Calvert Social Investment Fund The Calvert Fund Calvert Responsible Index Series, Inc. Calvert Impact Fund, Inc. Calvert Variable Series, Inc. Calvert World Values Fund, Inc. Calvert SAGE Fund Calvert Variable Products, Inc. Investment Companies 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Patrick Faul | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
John Nichols | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Rachel Volynsky | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Matthew Duch | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Vishal Khanduja | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Thomas A. Dailey | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Management Series Calvert Social Investment Fund The Calvert Fund Calvert Variable Series, Inc. Calvert Variable Products, Inc. Investment Companies 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer |
Robert J. Enderson | ||
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Lynne Ford | ||
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer and Director | |
Marybeth Pilat | ||
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Management Series Calvert Social Investment Fund The Calvert Fund Calvert Responsible Index Series, Inc. Calvert Impact Fund, Inc. Calvert Variable Series, Inc. Calvert World Values Fund, Inc. Calvert SAGE Fund Calvert Variable Products, Inc. Investment Companies 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Mary Rutford | ||
Calvert Investments, Inc. Holding Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Administrative Services, Inc. Service Company 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Services, Inc. Shareholder Servicing Agent 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Calvert Investment Distributors, Inc. Broker-Dealer 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Stu Dalheim |
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Laurie Webster | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer | |
Erica Lasdon | ||
Calvert Investment Management, Inc. Investment Advisor 4550 Montgomery Avenue Bethesda, Maryland 20814 | Officer |
(a) | Registrant's principal underwriter underwrites shares of the following investment companies other than Registrant: |
(b) | Positions of Underwriter's Officers and Directors |
Name and Principal Business Address* | Position(s) and Offices with Underwriter | Position(s) and Offices with Registrant |
John H. Streur | Director and Chief Executive Officer | Director and President |
Vicki L. Benjamin | Director, Executive Vice President, Chief Financial Officer, Chief Operating Officer, and Treasurer | Treasurer |
Lynne Ford | Director, Executive Vice President – Sales and Marketing | None |
Robert J. Enderson | Vice President, Corporate Finance, and Assistant Treasurer | Assistant Treasurer |
Marybeth Pilat | Assistant Treasurer and Anti-Money Laundering Officer | Fund Controller and Assistant Treasurer |
Mary Rutford | Assistant Secretary, Tax Accounting | None |
Alex Smith | Vice President, Investor Dealer Services | None |
Sonya Sbar | Vice President | None |
Quentin Anderson | Regional Vice President | None |
Anthony Eames | Senior Vice President | None |
Andrew Olig | Regional Vice President | None |
Penelope Jackson | Regional Vice President | None |
Andrew Niebler | Secretary and Vice President | Secretary and Vice President |
Robert D. Benson | Assistant Secretary and Assistant Vice President | Assistant Secretary and Assistant Vice President |
(c) | Inapplicable. |
Signature | Title |
__________**____________ John H. Streur | Director and Chair (Principal Executive Officer) |
__________**____________ Vicki L. Benjamin | Treasurer (Principal Financial Officer) |
__________**____________ Frank H. Blatz, Jr. | Director |
__________**____________ Arthur J. Pugh | Director |
__________**____________ Alice Gresham Bullock | Director |
__________**____________ M. Charito Kruvant | Director |
__________**_____________ Cynthia H. Milligan | Director |
__________**____________ William Lester | Director |
**By: /s/ Andrew K. Niebler |
Andrew K. Niebler |
Exhibit No. | Description |
28(p)(1) | Amended Code of Ethics for Calvert Funds et al. |
• | The interests of Calvert's Clients, including Calvert Fund shareholders, must be placed first at all times; |
• | All personal securities transactions must be conducted consistent with the Code and in such a manner as to avoid any actual or potential conflict of interest or any abuse of an individual’s position of trust and responsibility; |
• | Access Persons should not take inappropriate advantage of their positions; and |
• | Access Persons must comply with the applicable federal securities laws. |
1. | “Access Person” for the purposes of this Code, means all Calvert Associates and any trustee/director or officer of Calvert or the Calvert Funds. |
2. | “Automatic Investment Plan” means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. |
3. | A security is “being considered for purchase or sale” once a recommendation has been documented, communicated and under serious evaluation by the purchaser or seller. Evidence of consideration may include such things as approved recommendations in current research reports, pending or active order tickets, and a watch list of securities under current evaluation. |
4. | “Beneficial Interest” means a “direct or indirect pecuniary interest,” which is the opportunity to profit directly or indirectly from a transaction in securities. An Access Person is presumed to have a beneficial interest in securities held by members of his or her immediate family sharing the same household (i.e., spouse and children), or by certain partnerships, trusts, corporations, or other arrangements. See Rule 16a-1(a)(2) under the Securities Exchange Act of 1934. |
5. | “Brokerage Account” means an account held at a licensed/registered brokerage firm in which Securities may be bought and sold. |
6. | “Calvert Associate” or “Associate” means an employee of Calvert Investments, Inc. or any of its subsidiaries. |
7. | Chief Compliance Officer (“CCO”) means the Chief Compliance Officer of Calvert Investment Management, Inc., who shall be primarily responsible for administration of the Code, in consultation with the Chief Compliance Officers of Calvert Investment Distributors, Inc. and the Calvert Funds. |
8. | “Client” means (1) any investment company registered under the 1940 Act or series thereof for which Calvert Investment Management, Inc. serves as investment adviser and Calvert Investment Distributors, Inc. serves as underwriter and distributor (each a Calvert Fund and collectively the Calvert Funds); (2) any un-affiliated investment company registered under the 1940 Act or series thereof for which Calvert Investment Management, Inc. serves as investment adviser or sub-adviser; or (3) any separate account, separately managed account or other private account for which Calvert Investment Management, Inc. serves as adviser or sub-adviser. |
9. | “Control” means, among other things, the power to exercise a controlling influence over the management or policies of a company, unless such power is solely the result of an official position with such company. See Section 2(a)(9) of the 1940 Act. |
10. | “Independent Trustee/Director” means a Trustee or Director of a Calvert Fund who is not an “interested person” of the fund within the meaning of Section 2(a)(19) of the 1940 Act. |
11. | An “Initial Public Offering” or "IPO" means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934. |
12. | "Investment Personnel" with respect to any Client, means any Access Person who, in connection with his or her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities for that Client. |
13. | “Non-Employee Trustee/Director” means any Interested Trustee or Director of Calvert or the Calvert Funds who is not a Calvert Associate. |
14. | “Non-Reportable Securities” means: (1) direct obligations of the Government of the United States; (2) money market instruments -- bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments; (3) shares of money market funds; (4) shares of non-Calvert affiliated open-end investment companies; (5) holdings in 529 Plans if the Plan is invested exclusively in non-Calvert affiliated mutual funds; and (6) units of a unit investment trust if the unit investment trust is invested exclusively in non-Calvert affiliated mutual funds. |
15. | “PTA System” refers to the Personal Trading Assistant system, administered by SunGard, and implemented to automate the reporting requirements under the Code of Ethics (including processing of pre-clearance requests, quarterly and annual reporting, and annual certifications). |
16. | “Purchase or sale of a Security” includes, among other things, the writing of an option to purchase or sell a Security. |
17. | “Reportable Securities” means all Securities other than those listed above as Non-Reportable Securities. |
18. | “Security” means a security as defined in Section 202(a)(18) of the Advisers Act. |
• | Information concerning the purchase and sale of securities learned in connection with an Access Person’s employment is property of Calvert and/or its Clients and may not be used for personal benefit. |
• | Fiduciary duties mandate suitable investment opportunities be presented first to Calvert and its Clients and should only be exercised for personal benefit after full disclosure and approval from the CCO or designee. |
• | Material inside information must be kept confidential and restricts trading of securities. |
• | Front running, market manipulation and deceptive trading practices are abusive techniques prohibited by these procedures and may result in fines, termination or legal actions by Calvert or third parties. |
• | Access Persons must not engage in market timing of the Calvert Funds. This prohibition includes Calvert Funds held directly with Calvert as well as those held in any account in which the Access Person has Beneficial Interest (including 401(k) accounts). |
• | Access Persons are prohibited from purchasing Initial Public Offerings (“IPO”), which is a corporation’s first offering of stock to the public, including secondary issues of equity. |
• | Access Persons must not trade in a security based on knowledge that the security is being considered for purchase or sale for a Client. |
• | Access Persons must not engage in transactions that create a conflict of interest including but not limited to inappropriately making decisions on behalf of a Client regarding securities or private placements personally owned by the Access Person. |
• | The sale and/or purchase of Non-Reportable Securities (see definition above); |
• | Transactions in Calvert Funds; |
• | Transactions effected through an automatic investment plan (e.g., dividend reinvestment plan); |
• | Acquisitions through stock dividend plans, spin-offs or other distributions applied to all holders of the same class of securities (corporate actions); |
• | Acquisitions through gifts or bequests; |
• | Acquisitions pursuant to an automatic investment plan; or |
• | Trades in variable insurance products. |
2. | Discretionary Accounts |
• | A copy of the investment club's bylaws; |
• | Upon request, any additional information about the investment club, including a list of the members in the club and an indication if any members are employees or associated persons of Calvert or Ameritas; and |
• | The contact person for the investment club in case of questions. |
a. | The title, number of shares, and principal amount of each Reportable Security in which the Access Person has any direct or indirect Beneficial Interest, or over which the Access Person has the ability to exercise control/trading discretion; and |
b. | The name of any broker, dealer, or bank with whom the Access Person maintains an account in which any Reportable Securities were held for the direct or indirect benefit of the Access Person, or over which the Access Person has the ability to exercise control/trading discretion. |
• | in-person meeting with the CCO or designee, or the General Counsel to discuss compliance with the Code; |
• | imposition of additional restrictions (including prohibition) on personal securities transactions; |
• | notification to appropriate governmental, regulatory and/or legal authorities. |
(1) | trading by an insider, while in possession of material nonpublic information; or |
(2) | trading by a non-insider, while in possession of material nonpublic information, where the information either was disclosed to the non-insider in violation of an insider's duty to keep it confidential or was misappropriated; or |
• | civil injunctions; |
• | treble damages; |
• | disgorgement of profits; |
• | jail sentences; |
• | fines for the person who committed the violation of up to three times the profit gained or loss avoided, whether or not the person actually benefited; and |
• | fines for the employer or other controlling person of up to the greater of $1,000,000, or three times the amount of the profit gained or loss avoided. |
• | Obligation to Report Violations: Any Access Person who has himself or herself, or who discovers that another Access Person has, violated or apparently violated any provision of this Code of Ethics must promptly report the matter to the CCO. |
• | The CCO Has The Authority To Review Records: The CCO or designee may also request additional information to complete his or her compliance review and oversight. |
• | Your Privacy: Is extremely important and will be held in the utmost confidence, but your reported information is subject to review and action by regulators, and by appropriate personnel such as the CCO-Advisor, CCO-Distributor, CCO-Funds, and certain other members of the Legal and/or Compliance Departments. |
Securities Reporting for Access Persons | ||
This chart indicates which securities must be initially and annually reported and pre-cleared | Is Reporting Required? | Is Pre-clearance Required? |
American Depositary Receipts/Shares/Units (ADRs/ADSs/ADUs) | YES | YES |
Annuities – Fixed (other than market value adjusted annuities | NO | NO |
Annuities – Variable and Market value adjusted annuities | YES | NO |
Bonds and other debt instruments, including but not limited to Corporate, Municipal, Closely Held | YES | YES |
Bonds and other direct debt instruments of the U.S. Government: (e.g., Treasury notes, bills, bonds, TIPS or STRIPS), and U.S. Guaranteed or of federally sponsored enterprises (FHLMC, FNMA, GNMA, etc.) | NO | NO |
Bonds - convertible | YES | YES |
Bank certificates of deposit, Savings Certificates, checking and savings accounts and money market accounts. bankers’ acceptances, commercial paper and high quality short-term debt instruments, including repurchase agreements. | NO | NO |
Currency Accounts | YES | YES |
Derivatives (DECS, ELKS, PRIDES, etc.) | YES | YES (against both underlying stock & derivative) |
Futures (including options on): commodity, currency, financial, etc. | YES | YES |
Futures (including options on): index | YES | YES |
Exchange Traded Funds (ETFs) - (e.g., SPDRS/SPY, Diamonds/DIA, Cubes/QQQ, Holders Trusts, iShares, Power Shares) | YES | YES |
Initial Public Offerings (IPOs) | NO - PROHIBITED | |
Interests in 529 Plans with Calvert affiliated Mutual Funds | YES | NO |
Interests in 529 Plans with non-Calvert affiliated Mutual Funds | NO | NO |
Life Insurance (variable) | YES | NO |
Limited Offerings / Private Placements – Equity and Fixed Income | YES | YES |
Limited Partnerships | YES | YES |
Limit Order | YES | YES |
Open End Calvert Affiliated Mutual Funds | YES | NO |
Open End Non-Calvert Affiliated Mutual Funds | NO | NO |
Closed End Funds, including registered fund of hedge funds | YES | YES |
Options on stocks | YES | YES |
Options: exercise of option to buy or sell underlying stock | YES | YES |
REITS (Real Estate Investment Trusts) | YES | YES |
Stocks: common | YES | YES |
Stocks: preferred | YES | YES |
Stocks: short sales | YES | YES |
Stocks (owned: corporate actions) – exchanges, swaps, mergers, tender offers | YES | NO |
Stocks – public offerings (initial OR secondary) | NO-PROHIBITED | NO-PROHIBITED |
Stocks – Rights or warrants acquired separately | YES | YES |
Unit Investment Trusts (UITs) | YES | YES |
Foreign Currency Transactions | YES | NO |
Automatic Investment Plans | YES | NO |
Automatic Stock Purchase Plan Acquisitions | YES | NO |
Offshore Funds | YES | NO |
1. | I have retained you through [Name of 3rd Party Adviser’s Firm] to manage on a discretionary basis, the following accounts (the “Accounts”) where I have a beneficial interest and specified that I have no direct or indirect influence or control over the decisions related to the purchase or sale of particular securities in the Accounts. Specifically, with regards to the Accounts, I have certified that I have not directly or indirectly: |
• | Directed you to make any particular purchases or sales of securities; |
• | Suggested to you to make any particular purchases or sales of securities; |
• | Discussed with you the timing of any particular securities transaction or asset allocation decision. |
Account Number | Does Access Person have any direct or indirect influence or control |
2. | That if my ability to directly or indirectly influence or control the Accounts should change in any way, I will immediately notify Calvert’s Chief Compliance Officer in writing of such a |
3. | I agree to provide reports of holdings and transactions made in the Accounts. |
Account Number | Does Access Person have any direct or indirect influence or control |
• | Direct me to make any particular purchases or sales of securities; |
• | Suggest to me to make any particular purchases or sales of securities; |
• | Discuss with me the timing of any particular securities transaction or asset allocation decision. |
Compliance Department Certification: | [Name of Compliance Individual] |
By signing, we are certifying that [Name of 3rd Party Adviser’s Firm] compliance department is aware of this certification and believe to best of knowledge that it to be true. | __________________________________ |
Date: |
Calvert Associate Name | Compliance Date |