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Introduction
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4
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Standards of Business Conduct
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5
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Applicability and Scope
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5
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Access Levels
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6
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Access Level 1
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6
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Access Level 2
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7 |
Access Level 3
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7
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Overview of Rules for All Access Persons
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7
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Brokerage Account Disclosure
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7
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Brokerage Account Examples (non-exclusive list)
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7
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Employee Compensation Instruments (non-exclusive list)
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8
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College Savings Plans - 529s
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8
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401(k) and John Hancock Variable Products: John Hancock Affiliated Funds Reporting
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9
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Managed Accounts
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9
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Preferred Brokerage Account Requirements
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9
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Opening/Closing Accounts
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10 |
Statements and Duplicate Confirmations of Trades
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10
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Personal Trading
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10
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Personal Trading Restrictions for all Access Persons
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11
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Reporting and Pre-clearance
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11
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Level 1 Access Persons: Additional Personal Trading Restrictions and Disclosures
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12
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Level 2 Access Persons: Additional Personal Trading Restrictions and Disclosures
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15
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Level 3 Access Persons: Additional Personal Trading Restrictions and Disclosures
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17
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Pre-clearance Process
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17
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Reporting and Certification Requirements
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18
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Reporting
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18
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Reporting Upon Designation
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18
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Quarterly Reporting
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18
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Annual Reporting
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19
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Ad Hoc Reporting
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19
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Administration and Enforcement
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20
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Administration of the Code
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20
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Subadviser Compliance
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20
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Adoption and Approval
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20
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Subadviser Reporting & Recordkeeping Requirements
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21
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Reporting to the Board
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21
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Reporting Violations
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21
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Exemptions & Appeals
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22
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Exemptions:
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22
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Appeals
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22
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Interpretation and Enforcement
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22
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Education of Employees
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23
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Recordkeeping
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23
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Other Important Policies
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24
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MFC Code of Business Conduct & Ethics (All Covered Employees)
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24
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John Hancock Conflicts of Interest Policy (All Covered Employees)
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25
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John Hancock Gift & Entertainment Policy (All Covered Employees)
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25
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John Hancock Insider Trading Policy (All Covered Employees)
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25
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John Hancock Pay to Play Rule on Political Contributions (All Covered Associates)
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25
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John Hancock Whistleblower Policy (All Covered Employees)
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26
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Policy and Procedures Regarding Disclosure of Portfolio Holdings (All Covered Employees)
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26
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Additional Policies Outside the Code (All Covered Employees)
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27
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Appendix
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28
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Definitions
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28
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Preferred Brokers List
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32
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Compliance Contacts
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33
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Place the interests of clients first. You have a fiduciary duty at all times to place the interests of our clients and
fund investors first.
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Conduct all personal trading in full compliance with this Code. All of your personal securities transactions must be
conducted consistent with the provisions of the Code that apply to you and in such a manner as to avoid any actual or potential conflict of interest or other abuse of your position of trust and responsibility.
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Avoid taking inappropriate advantage of your position at John Hancock. You should not take inappropriate advantage of
your position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to our clients’ accounts or fund investors.
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Maintain confidentiality of our clients and John Hancock. You must treat as confidential any information concerning
the identity of security holdings and financial circumstances of clients or fund investors.
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Comply with applicable Federal Securities Laws. You must comply with all applicable federal Securities Laws.
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Report any violation of the Code. You must promptly report any violation of the Code that comes to your attention to
the CCO (or designee) of your company.
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a director, officer or other Supervised Person of a John Hancock Adviser;
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an interested director, officer or Access Person of John Hancock Investment Management Distributors, LLC, John Hancock Distributors, LLC, or a John Hancock
open-end or closed-end fund registered under the 1940 Act and are advised by a John Hancock Adviser;3
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an employee of Manulife Financial Corporation (MFC) or its subsidiaries who participates in making recommendations for, or receives information about,
portfolio trades or holdings of the John Hancock Affiliated Funds.4
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Portfolio Managers
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Analysts
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Traders
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Office of the CCO
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Fund Administration
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Investment Management Services
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Technology Resources Personnel (as designated)
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Legal Staff
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Marketing (as designated)
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Marketing (as designated)
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Product Development
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E-Commerce
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Corporate Publishing
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Technology Resources Personnel (as designated)
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of your own; regardless of what is currently held in the account,
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of your spouse, Significant Other, minor children or family members sharing the same household (Household Family Member),
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over which you have discretion or give advice or information, and/or
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in which your Household Family Member have Beneficial Ownership, or the opportunity to directly or indirectly profit or share in any profit derived from a
Reportable Securities transaction.
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Brokerage Accounts
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John Hancock 401(k) accounts
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MFC Global Share Ownership Plan (GSOP)
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Solium accounts (some if they hold reportable securities including options on MFC securities)
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Self-directed IRA accounts
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Custodial accounts
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Mutual fund accounts*
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College investment plans 529s*
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401(k)/403(b) accounts*
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Dividend reinvestment program or dividend reinvestment plan (DRIP)
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Registered Retirement Savings Plan (RRSP/RESP/TFSA)
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Stock Purchase accounts
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John Hancock 401(k)
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MFC Global Share Ownership Plan (GSOP)
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Options acquired from MFC (only MFC Solium account options that are granted)
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Public company employer as part of employee compensation
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Sole discretion accounts
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Accounts holding John Hancock Affiliated Funds
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Certain Manulife Pension Plans (RPS, RRSP)
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MFC Restricted Share Units (RSU)
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Deferred Share Units (DSU)
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Performance Share Units (PSU)
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US John Hancock Pension Plans
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Employer phantom stock/phantom option interest (granted as compensation to employee, only employer can redeem interest and interest is non-transferrable)
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1) |
Suggest that the trustee or third-party discretionary manager make any particular purchases or sales of Reportable Securities;
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2) |
Direct the trustee or third-party discretionary manager to make any particular purchases or sales of Reportable Securities; and
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3) |
Consult with the trustee or third-party discretionary manager as to the particular allocation of investments to be made in your account.
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Are required to notify the Code of Ethics Administration team within 10 days of opening or closing a Brokerage Account. In the case of a new Brokerage Account
in which you have a beneficial interest, you must notify the Code of Ethics Administration Group before any trades are placed.
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Are required by this Code and by the Insider Trading Policy to inform your broker-dealer that you are employed by a financial institution. Your broker- dealer
is subject to certain rules designed to prevent favoritism toward your Brokerage Accounts. You may not accept negotiated commission rates that you believe may be more favorable than the broker grants to accounts with similar
characteristics.
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Must notify the broker-dealer if you are registered with the Financial Industry Regulatory Authority or are employed by John Hancock Investment Management
Distributors, LLC or John Hancock Distributors, LLC.
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Disclose holdings in Reportable Securities (including John Hancock Affiliated Funds and John Hancock Variable Products)
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Disclose Brokerage Accounts
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Pre-clear applicable Reportable Securities transactions
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Profiting from the purchase and sale of a John Hancock Affiliated Fund within 30 calendar days.
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Engaging in speculative transactions involving MFC securities including: options, hedging or short sales involving securities issues by Manulife.
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Transacting in securities that appear on the confidential John Hancock Restricted list (pre-clearance requests will be denied).
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Transacting in Initial Public Offerings (IPOs), Private Placements, and Limited Offerings without obtaining proper pre-clearance approval.6
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Transacting in securities while in possession of material nonpublic information including but not limited to: fund events, due diligence visits etc.
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Pre-clear MFC Securities: You must pre-clear all transactions in MFC securities including stock, company issued
options, securities such as debt, and sell transactions in the MFC Global Share Ownership Plan.
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Pre-clear all of the following securities: You must pre-clear and receive approval prior to transactions in the
following securities:
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Stocks; including sell transactions of MFC Shares held in your Global Share Ownership Plan
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Bonds;
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Government securities that are not direct obligations of the U.S. government, such as Fannie Mae, or municipal securities, in each case that mature in more
than one year;
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John Hancock Affiliated Funds;7
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Closed-end funds (including John Hancock affiliated closed-end funds)
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Options on securities, on indexes, and on currencies;
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Swaps on securities, on indexes, and on currencies;
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Limited partnerships;
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Exchange traded funds and notes;
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Domestic unit investment trusts;
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Non-US unit investment trusts and Non-US mutual funds;
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Private investment funds and hedge funds; and
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Futures, investment contracts or any other instrument that is considered a “security” under the Securities Act of 1933;
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Private Placements, limited offerings8.
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Ban on IPOs: You may not acquire securities in an IPO. You may not purchase any newly-issued Reportable Security until
it is listed on a public exchange.
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Seven Day Blackout: You are prohibited from buying or selling a Reportable Security within 7 calendar days before or
after that Reportable Security is traded for a fund that the Person manages or for a John Hancock Affiliated Fund unless no conflict of interest exists in relation to that Reportable Security as determined by the Code of Ethics
Administration Group.
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Gifting Reportable Securities: If you gift or donate shares of a Reportable Security it is considered a sale and you
must receive pre-clearance approval.
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Inheriting Reportable Securities: If you inherit shares of a Reportable Security you must notify the Code of Ethics
Administration Group within 10 days.
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30 Day Hold John Hancock Affiliated Funds: You cannot profit from the purchase and sale of a John Hancock Affiliated
Funds within 30 calendar days.
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60 Day Hold: You may not profit from the purchase and sale (or sale and purchase) of the same (or equivalent)
Reportable Security (see note on John Hancock Affiliated Funds) within 60 calendar days, also known as a “Ban on Short Term Profits”.
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Exclusion: pre-clearance requests in a Reportable Security with a market capitalization of $5 billion or more would, in most cases, not be subject to the 60
day hold and would be approved if they are appropriately pre-cleared.
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Ownership Ban: Securities of Sub-advisers: you are prohibited from owning securities of any sub-adviser of a John
Hancock Affiliated Fund.9
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Must promptly disclose:
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Ownership of Securities Under Consideration for John Hancock Affiliated Fund:
Any direct or indirect beneficial interest in a Reportable Security that is under consideration for purchase or sale in a John Hancock Affiliated Fund.
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Private Placement Conflicts: You must disclose holdings of any Reportable Securities purchased in a private placement
when you participate in a decision to purchase or sell that same issuer’s securities for a John Hancock Affiliated Fund.
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Restriction on Securities Under Active Consideration: You are prohibited from buying or selling a Reportable Security
if the Reportable Security is being actively traded by a John Hancock Affiliated Fund.
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Exceptions:
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De Minimis Trading: pre-clearance requests for 500 shares or less of a particular Reportable Security within a market
value of $25K or less, aggregated daily, would, in most cases, not be subject to the 7-day blackout period restrictions and the restriction on actively traded securities.
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Market Cap Securities: pre-clearance requests in a Reportable Security with a market capitalization of $5B or more
would not be subject to the blackout period restrictions and the restriction on actively traded securities.
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Pre-clearance of Exchange Traded Funds/Exchange Traded Notes (ETF/ETN) and Options on Reportable Securities: you are
required to pre-clear ETFs, ETNs and Options on Reportable Securities.
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Exceptions to the pre-clearance requirement for ETF/ETN or options on Reportable Securities (provided it is not a John Hancock Affiliated Fund):
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has an average market capitalization of $5 billion or more;
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is based on a non-covered security;
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or is based on a Broad-Based Index.
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Prohibition on Investment Clubs, Good Until Canceled Orders, or Limit Orders: You may not participate in:
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investment clubs,
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“good until cancelled orders”, or
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“limit orders” unless the limit orders are day orders that automatically expire at the end of the trading day and cancel any orders that have not been
executed.
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Ownership of 5% or Greater: 5% or greater interest in a company, John Hancock Affiliated Funds and its affiliates may
not make any investment in that company;
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Ownership of 1% or greater 1% or greater interest in a company, you cannot participate in any decision by John Hancock
Funds and its affiliates to buy or sell that company’s securities;
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ANY other interest in a company, you cannot recommend or participate in a decision by John Hancock Affiliated Funds,
and its affiliates to buy or sell that company’s securities unless your personal interest is fully disclosed at all stages of the investment decision.
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Pre-clear MFC Securities: You must pre-clear all transactions in MFC securities including stock, company issued
options, sell transactions in the MFC Global Share Ownership Plan, and any other securities such as debt.
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Pre-clear the following securities: You must pre-clear and receive approval prior to transactions in the following
securities:
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Stocks; including sell transactions of MFC Shares held in your Global Share Ownership Plan
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Bonds;
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Government securities that are not direct obligations of the U.S. government, such as Fannie Mae, or municipal securities, in each case that mature in more
than one year;
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John Hancock Affiliated Funds;10
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Closed-end funds (including John Hancock affiliated closed-end funds)
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Options on securities, on indexes, and on currencies;
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Swaps on securities, on indexes, and on currencies;
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Limited partnerships;
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Exchange traded funds and notes;
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Domestic unit investment trusts;
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Non-US unit investment trusts and Non-US mutual funds;
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Private investment funds and hedge funds; and
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Futures, investment contracts or any other instrument that is considered a “security” under the Securities Act of 1933;
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IPOs11, Private Placements, limited offerings.
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Three Day Blackout Period: You are prohibited from knowingly buying or selling a Reportable Security within three
calendar days before and after that Reportable Security is traded for a John Hancock Affiliated Fund unless no conflict of interest exists in relation to that Reportable Security as determined by the Code of Ethics Administration Group.
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Gifting Reportable Securities: If you gift or donate shares of a Reportable Security the transaction is considered a
sale and you must receive pre-clearance approval.
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Inheriting Reportable Securities: If you inherit shares of a Reportable Security you must notify the Code of Ethics
Administration Group within 10 days.
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30 Day Hold John Hancock Affiliated Funds: You cannot profit from the purchase and sale of a John Hancock Affiliated
Funds within 30 calendar days.
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60 Day Hold: You may not profit from the purchase and sale (or sale and purchase) of the same (or equivalent)
Reportable Security within 60 calendar days, also known as a “Ban on Short Term Profits”.
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Exclusion: pre-clearance requests in a Reportable Security with a market capitalization of $5 billion or more would, in most cases, not be subject to the Ban
on Short Term Profits, and would be approved if they are appropriately pre-cleared.
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Ownership Ban: Securities of Sub-advisers: you are prohibited from owning securities of any sub-adviser of a John
Hancock Affiliated Fund.12
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Restriction on Securities Under Active Consideration: You are prohibited from buying or selling a Reportable Security
if the security is being actively traded by a John Hancock Affiliated Fund.
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Exceptions:
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De Minimis Trading: pre-clearance requests for 500 shares or less of a particular Reportable Security within a market
value of $25K or less, aggregated daily, would, in most cases, not be subject to the 7-day blackout period restrictions and the restriction on actively traded securities.
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◾ |
Market Cap Securities: pre-clearance requests in a Reportable Security with a market capitalization of $5B or more
would not be subject to the blackout period restrictions and the restriction on actively traded securities.
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Pre-clearance of Exchange Traded Funds/Exchange Traded Notes (ETF/ETN) and Options on Reportable Securities: you are
required to pre-clear ETFs, ETNs and Options on Reportable Securities.
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Exceptions to the pre-clearance requirement for ETF/ETN or options on Reportable Securities (provided it is not a John Hancock Affiliated Fund):
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has an average market capitalization of $5 billion or more;
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is based on a non-covered security;
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◾ |
or is based on a Broad-Based Index.
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Prohibition on Investment Clubs, Good Until Canceled Orders, or Limit Orders: You may not participate in:
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investment clubs,
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“good until cancelled orders”, or
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“limit orders” unless the limit orders are day orders that automatically expire at the end of the trading day and cancel any orders that have not been
executed.
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Pre-clear
transactions in:
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closed-end funds and exchange traded funds advised by a John Hancock Adviser
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transactions in IPOs
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private placements and limited offerings.
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Gift or Donation of Reportable Securities: You must obtain pre-clearance approval prior to gifting or donating any
Reportable Securities transactions that would require pre-clearance.
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Inheritance of Reportable Securities: If you inherit shares of a Reportable Security you must notify the Code of
Ethics Administration Group within 10 days.
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30 Day Hold John Hancock Affiliated Funds: You cannot profit from the purchase and sale of a John Hancock Affiliated
Funds within 30 calendar days.
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You may not trade until clearance approval is received.
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Clearance approval is valid only for the date granted (i.e. the pre-clearance requested date and the trade date should be the same).
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A separate procedure should be followed for requesting pre-clearance of an IPO, a private placement, or a limited offering in StarCompliance.
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Initial Holdings Report: A report of all Brokerage Accounts (please see the definition section) that hold or have the
ability to hold any Reportable Securities and all Reportable Securities holdings current as of the date you became an Access Person.
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Initial Certification of Compliance: Certify to your understanding of the Code of Ethics.
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Initial Training: Certify that you have attended a training on the Code of Ethics Policy.
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Quarterly Certification: a report of all Brokerage Accounts and all transactions in Reportable Securities (including
transactions in John Hancock Affiliated Funds, including sell transactions in your Global Share Ownership Plan (GSOP) and voluntary transactions, such as fund exchanges, in your John Hancock 401(k)).
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Managed Account Certification: A certification of related to your Managed Accounts (only if applicable).
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All transactions in John Hancock Affiliated Funds and Variable Products must be reported.
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Only sell transactions of MFC stock in your Global Share Ownership Plan (GSOP) need to be reported.
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Only voluntary transactions, such as fund exchanges, need to be reported for transactions in your John Hancock 401(k) Savings account.
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Account number
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Brokerage Firm
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the date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and
principal amount of each Reportable Security involved;
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the nature of the transaction (i.e. purchase, sale or any other type of acquisition or disposition);
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the price at which the transaction was effected;
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the name of the broker, dealer or bank with or through which the transaction was effected.
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Annual Holdings Report: disclosing all of your Brokerage Accounts that hold or can hold any Reportable Securities and
all holdings in Reportable Securities, current as of a date not more than 45 days before the report is submitted.
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John Hancock Affiliated Funds & Variable Products holdings must be reported, regardless of where they are held.
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Global Share Ownership holdings of Manulife Financial Corporation, Inc. (MFC) stock must be reported.
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Annual (or additionally when the Code has been materially changed) Certification of Code of Ethics: acknowledging that
you have received, read, and complied with the requirements of the Code of Ethics.
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Brokerage Account Changes: You are required to promptly notify (within 10
days) Compliance of any applicable account changes.
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Changes to the Code of Ethics: You are required to complete an additional certification of compliance stating that
you read, received and understood material changes to the Code of Ethics.
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The sub-adviser must have adopted their own code of ethics in accordance with Rule 204A-1(b) under the Advisers Act which has been approved by the Board of
Trustees;
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• |
On a quarterly basis, each sub-adviser certifies compliance with their Code of Ethics or reports material violations if such have occurred; and
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• |
Each sub-advisor must report quarterly to the CCO (or designee), any material changes to its Code of Ethics.
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Contains provisions reasonably necessary to prevent the subadviser’s Access Persons (as defined in Rule 17j-1 under the 1940 Act and Rule 204A-1 under the
Advisers Act) from engaging in any conduct prohibited by Rule 17j-1 and 204A-1;
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Requires the sub-adviser’s Access Persons to make reports to at least the extent required in Rule 17j-1(d) and Rule 204A-1(b);
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• |
Requires the sub-adviser to institute appropriate procedures for review of these reports by management or compliance personnel (as contemplated by Rule
17j-1(d)(3) and Rule 204 A- 1(a)(3));
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• |
Provides for notification of the sub-adviser’s Access Persons in accordance with Rule 17j-1(d)(4) and Rule 204A-1(a)(5);
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• |
Requires the sub-adviser’s Access Persons who are Investment Personnel to obtain the pre- clearances required by Rule 17j-1(e); and
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Requires the sub-adviser’s Access Persons to obtain the pre-clearances required by Rule 204A- 1(c).
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describes issues that arose during the previous year under the Code of Ethics or the related procedures, including, but not limited to, information about
material Code or procedure violations, as well as any sanctions imposed in response to the material violations, and
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• |
certifies that each entity, including the sub-advisers have adopted procedures reasonably necessary to prevent its Access Persons from violating its Code of
Ethics,
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• |
Any material changes to the Code are presented to the Trustees within six months for their approval.
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• |
a doubt about a particular situation;
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• |
a question or concern about a business practice; or
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• |
a question about potential conflicts of interest
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the person's position and function (senior personnel may be held to a higher standard);
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• |
the amount of the trade;
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• |
whether the John Hancock Affiliated Funds hold the security and were trading the same day;
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• |
whether the violation was by a family member;
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• |
whether the person has had a prior violation and which policy was involved; and
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• |
whether the employee self-reported the violation.
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• |
Copy of the current Code for John Hancock and a copy of each Code of Ethics in effect at any time within the past five years.
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• |
Record of any violation of the Code, and of any action taken as a result of the violation, for six years.
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• |
Copy of each report made by an Access Person under the Code, for six years (the first two years in a readily accessible place).
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Record of all persons, currently or within the past five years, who are or were, required to make reports under the Code. This record will also indicate who
was responsible for reviewing these reports.
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• |
Record of any decision, and the reasons supporting the decision, to approve the acquisition by an Access Level I Persons of IPOs or private placement
securities, for six years.
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• |
Record of any decision, and the reasons supporting the decision, to approve the acquisition by an Access Person of the John Hancock Advisers IPOs or private
placement securities, for six years.
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• |
MFC values;
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• |
Ethics in workplace;
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• |
Ethics in business relationships;
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• |
Conflicts of Interest;
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• |
Handling information;
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• |
Receiving or giving of gifts, entertainment or favors;
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• |
Misuse or misrepresentation of your corporate position;
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• |
Disclosure of confidential or proprietary information;
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• |
Disclosure of outside business activities;
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• |
Antitrust activities; and
|
• |
Political campaign contributions and expenditures relating to public officials.
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Gift & Business Entertainment Limits
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• |
Restrictions on Gifts & Entertainment
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• |
Reporting of Gifts & Entertainment
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• |
Possession, misuse and access to material nonpublic information
|
• |
A two-year prohibition on an adviser’s providing compensated investment advisory services to a government entity after a contribution has been made by the
adviser or one of its covered associates;
|
• |
A prohibition on the use of third-party solicitors who are not themselves regulated persons subject to pay-to-play restrictions on political contributions;
and
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• |
A prohibition on bundling and other efforts by advisers to solicit political contributions to certain officials of a government entity to which the adviser is
seeking to provide services.
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Policy Regarding Dissemination of Mutual Fund Portfolio Information
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• |
Manulife Financial Corporation Anti-Fraud Policy
|
• |
John Hancock Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Program
|
• |
Conflict of Interest Rules for Directors and Officers
|
• |
John Hancock Non-Cash Compensation Policy
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the S&P 100, S&P Midcap 400, S&P 500, FTSE 100, and Nikkei 225;
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Direct obligations of the U.S. Government (e.g., treasury securities)
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Indirect obligations of the U.S. Government with a maturity of less than 1 year (GNMA)
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Commodities;
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Foreign currency
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Which have the capability to hold Reportable Securities;
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Accounts of your spouse, Significant Other, minor children or family members sharing your household (together, “Household Members”);
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Accounts in which you or your Household Members have a Beneficial Ownership;
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Accounts over which you have discretion, give advice or information or have Power of Attorney (POA).
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transactions which result from a corporate action applicable to all similar security holders (such as splits, tender offers, mergers, stock dividends, etc.);
or
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automatic dividend reinvestment and stock purchase plan acquisitions.
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a “John Hancock Mutual Fund” (i.e., a 1940 Act mutual fund that is advised or sub-advised by a John Hancock Adviser or by another Manulife entity); or
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“John Hancock Variable Product” (i.e., contracts funded by insurance company separate accounts that use one or more portfolios of John Hancock Variable
Insurance Trust).
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Any other financial product or security advised or sub-advised by a John Hancock Adviser or John Hancock Insurance or another Manulife entity.
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Ameriprise
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Sanders Morris Harris
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Bank of Oklahoma
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Scottrade
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Bank of Texas
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Stifel
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Barclays Wealth Management
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TD Ameritrade
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Brave Warrior Advisors
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T. Rowe Price
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Charles Schwab
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Thompson Davis & Co.
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Chase Investment Services
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UBS
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Citigroup
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US Trust
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Constellation Wealth Management
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Vanguard
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Credit Suisse
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Robert W. Baird & Co.
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DB Alex Brown
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Edward Jones
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E*Trade
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Fidelity
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First Republic
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Goldman Sachs Wealth Management
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HSBC Private Bank
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Interactive Brokers
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JB Were
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JP Morgan Private Bank
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JP Morgan Securities
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Lincoln Financial
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Merrill Lynch & Bank of America
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Morgan Stanley Private Wealth
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Morgan Stanley Smith Barney
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Northern Trust
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Northern Trust Institutional
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Oppenheimer & Co.
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OptionsXpress
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Pershing Advisor Solutions
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Piper Jaffray
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Raymond James
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Revolution Capital
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Entity
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Chief Compliance Officer
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John Hancock Investment Management, LLC
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Trevor Swanberg – 617-572-4398
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John Hancock Variable Trust Advisers, LLC
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Trevor Swanberg
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Each open-end and closed-end fund advised by a John Hancock Adviser
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Trevor Swanberg
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John Hancock Investment Management Distributors, LLC
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Michael Mahoney - 617-663-3021
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John Hancock Distributors, LLC
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Michael Mahoney
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Code of Ethics Contacts
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E-mail
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Code of Ethics Administration Group
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INVDIVCodeofEthics@manulife.com
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