N-CSR

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES

Investment Company Act file number: (811- 06190 )

Exact name of registrant as specified in charter: Putnam International Equity Fund

Address of principal executive offices: One Post Office Square, Boston, Massachusetts 02109

Name and address of agent for service: Beth S. Mazor, Vice President
One Post Office Square
Boston, Massachusetts 02109

Copy to: John W. Gerstmayr, Esq.
Ropes & Gray LLP
One International Place
Boston, Massachusetts 02110

Registrant’s telephone number, including area code: (617) 292-1000

Date of fiscal year end: June 30, 2006

Date of reporting period: July 1, 2005—June 30, 2006

Item 1. Report to Stockholders:
The following is a copy of the report transmitted to stockholders pursuant
to Rule 30e-1 under the Investment Company Act of 1940:

What makes Putnam different?

In 1830, Massachusetts Supreme Judicial Court Justice Samuel Putnam established The Prudent Man Rule, a legal foundation for responsible money management.

THE PRUDENT MAN RULE

All that can be required of a trustee to invest is that he shall conduct himself faithfully and exercise a sound discretion. He is to observe how men of prudence, discretion, and intelligence manage their own affairs, not in regard to speculation, but in regard to the permanent disposition of their funds, considering the probable income, as well as the probable safety of the capital to be invested.

A time-honored tradition
in money management
Since 1937, our values have been rooted
in a profound sense of responsibility for the
money entrusted to us.

A prudent approach to investing
We use a research-driven team approach to seek
consistent, dependable, superior investment
results over time, although there is no guarantee
a fund will meet its objectives.

Funds for every investment goal
We offer a broad range of mutual funds and other
financial products so investors and their financial
representatives can build diversified portfolios.

A commitment to doing
what’s right for investors
We have below-average expenses and stringent
investor protections, and provide a wealth of
information about the Putnam funds.

Industry-leading service
We help investors, along with their financial
representatives, make informed investment
decisions with confidence.

Putnam

International

Equity Fund

6| 30| 06

Annual Report

Message from the Trustees	2
About the fund	4
Report from the fund managers	7
Performance	13
Expenses	16
Portfolio turnover	18
Risk	19
Your fund’s management	20
Terms and definitions	23
Trustee approval of management contract	25
Other information for shareholders	30
Financial statements	31
Federal tax information	59
Brokerage commissions	60
About the Trustees	61
Officers	67

Cover photograph: © Marco Cristofori

Message from the Trustees

Dear Fellow Shareholder

Over the last two months of your fund’s reporting period, investors were particularly preoccupied with the course of the economy. A more pessimistic outlook pervaded the markets in May and June as leading economic indicators began to warn of slower growth and the Federal Reserve (the Fed) continued its series of interest-rate increases. The resulting correction undercut much of the progress that markets had achieved in the first four months of 2006.

However, we believe that today’s higher interest rates, far from being a threat to global economic fundamentals, are in fact an integral part of them. These higher rates are bringing business borrowing costs closer to the rate of return available from investments. At some point, this could mean that economic growth may, indeed, slow somewhat, but we consider this a typical development for the middle of an economic cycle, and one that could help provide the basis for a longer and more durable business expansion and a continued healthy investment environment.

The recent correction has, in our view, brought valuations back to attractive levels and created opportunities in a wide array of markets and sectors. You can be assured that the investment professionals managing your fund are working to take advantage of these opportunities as they arise. Moreover, Putnam Investments’ management team, under the leadership of Chief Executive Officer Ed Haldeman, continues to focus on investment performance and remains committed to putting the interests of shareholders first.

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We would like to take this opportunity to announce the retirement of one of your fund’s Trustees, John Mullin, who has been an independent Trustee of the Putnam funds since 1997. We thank him for his service. In the following pages, members of your fund’s management team discuss the fund’s performance and strategies for the fiscal period ended June 30, 2006, and provide their outlook for the months ahead. As always, we thank you for your support of the Putnam funds.

Putnam International Equity Fund: the benefits of investing in international stock markets

As a shareholder of Putnam International Equity Fund, you are positioning your money to benefit from investment opportunities outside the United States. Although international investing involves additional risks, the fund lets you take advantage of the capital appreciation potential of a broad range of leading companies in international markets.

In many cases, international companies are the top competitors in global industries. If you look at the products or services you use every day — from cars to cellular telephones to household products — you are likely to find many items made by international companies.

While investing in different currencies and economic systems can add risk, it may help you manage an important financial risk — the possibility of a slump in the U.S. economy —and gives you a chance to keep building wealth even if U.S. stocks struggle.

That’s because international economies generally follow a different business cycle than the United States and have different monetary policies. In many regions, especially Asia and Latin America, economies are growing much faster than the U.S. economy and appear likely to continue this growth at an accelerated pace. And, when you invest internationally, you can benefit when foreign currencies strengthen against the U.S. dollar.

Since 1991, Putnam International Equity Fund has sought to invest in leading companies in international markets. The fund’s management team analyzes stocks, as well as industry sectors and global market conditions, by relying on Putnam’s proprietary research capabilities. In addition to the United States, analysts and other team members are based in London and Tokyo for better access to information about international companies.

Many changes in the world economy have added to
the investment potential of international companies since
Putnam International Equity Fund launched in 1991.

Using Putnam’s blend strategy, the team has the flexibility to select a broad range of stocks it believes are priced below their true worth. The portfolio’s diversification may help keep the fund competitive given the risks of changing market conditions and political developments in international markets. The fund can invest in developed economies such as Europe, Japan, Canada, and Australia, as well as in the emerging markets of the world. For 15 years, the fund has helped investors benefit from diversification and economic growth generated outside the United States.

Additional risks may be associated with emerging-market securities, including illiquidity and volatility. The fund invests some or all of its assets in small and/or midsize companies. Such investments increase the risk of greater price fluctuations. While diversification can help protect your returns from excessive volatility, it cannot protect against market losses.

A rising equity culture
fuels the growth of
international markets.

Many analysts believe that as equity markets expand an “equity culture” forms. In an equity culture, people accept the risk of owning stocks in exchange for the opportunity to earn long-term finan-cial rewards. Signs of a flourishing equity culture include the creation of new markets and investor-friendly regulations.

New markets for equity investing were established as communist economies transitioned to capitalism. In 1989, for example, Slovenia established a stock exchange, followed by Hungary, China, and more than five other nations by 1992.

Investor-friendly regulations help to give investors a sound legal footing. Examples include South Korea’s measures requiring companies to respect minority-shareholder rights, grant real power to independent directors, and open up to foreign ownership.

Putnam International Equity Fund seeks capital appreciation by

investing primarily in common stocks of companies outside the United States. Without a predetermined bias toward growth or value stocks, the fund targets large and midsize companies priced below what we believe they are worth. It may be suitable for investors seeking capital appreciation who are willing to accept the risks of investing in international markets.

Highlights

* Putnam International Equity Fund’s class A shares returned 25.70% without sales charges for
the 12 months ended June 30, 2006.

* The fund’s benchmark, the MSCI EAFE Index, returned 26.56% for the period.

* The fund’s Lipper peer group, International Large-Cap Core Funds, had an average return of
25.67% for the period.

*  Additional fund performance, comparative performance, and Lipper data can be found in the
performance section beginning on page 13.

Performance

Total return for class A shares for periods ended 6/30/06

Since the fund’s inception (2/28/91), average annual return is 10.73% at NAV and 10.34% at POP.

	Average annual return		Cumulative return
	NAV	POP	NAV	POP
10 years	10.43%	9.83%	169.63%	155.47%
5 years	7.44	6.29	43.18	35.65
3 years	20.30	18.15	74.11	64.93
1 year	25.70	19.08	25.70	19.08

Data is historical. Past performance does not guarantee future results. More recent returns may be less or more than those shown. Investment return and principal value will fluctuate, and you may have a gain or a loss when you sell your shares. Performance assumes reinvestment of distributions and does not account for taxes. Returns at NAV do not reflect a sales charge of 5.25% . For the most recent month-end performance, visit www.putnam.com. For a portion of the period, this fund limited expenses, without which returns would have been lower. A short-term trading fee of up to 2% may apply.

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Report from the fund managers

The year in review

During the fiscal year that ended June 30, 2006, Putnam International Equity Fund achieved robust results. The fund’s performance at net asset value (NAV, or without sales charges) was in line with the average for its Lipper peer group and just slightly behind the return of its benchmark index. Our stock selections proved particularly rewarding in the energy, consumer staples, and health-care sectors. However, these gains were offset by weak performance from several stocks in France and the United Kingdom. The fund’s currency positioning was beneficial primarily because of overweight exposure to the Brazilian real, which strengthened versus the U.S. dollar.

Market overview

International stocks delivered substantially stronger results than U.S. stocks over the past fiscal year. Supported by an accelerating global economy, which grew at a pace of more than 4% annually, most international markets posted double-digit gains. A reinvigorated Japan led the way. In sector terms, basic materials, capital goods, energy, and financials delivered the best results. Only the communications services sector posted a negative return for the trailing 12 months.

Economic activity in Europe has recently gathered pace while brisk merger-and-acquisitions (M&A) activity continues to lift equities. However, worries about the long-term effects of high energy prices and the European Central Bank’s tighter monetary policy could threaten future momentum. While the Japanese economy continued to show signs of recovery, a June insider-trading scandal contributed to a recent pullback there. The Bank of Japan remained patient during the period, but after the period ended, further indications of improving economic activity prompted the Bank to lift interest rates to 0.25% from 0.1%, the level at which they had been set since 2001. We believe the rate increase is a sign of the bank’s confidence in the continuation of Japan’s recovery.

In light of the solid gains achieved over the trailing 12 months, we believe

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the recent pullback in global markets can be attributed to investor concern about the possibility of inflation, higher interest rates in several markets, and the vulnerability of crude oil prices and supplies to geopolitical events.

Strategy overview

In managing your fund’s portfolio, our approach focuses on stock selection. We seek to own stocks of large and mid-size international companies mispriced by the market — in other words, companies that we believe are worth more than their current stock prices indicate, based on the cash flow the companies generate. The fund’s “blend” investment style gives us the flexibility to invest in a wide range of companies without a bias toward either growth or value stocks. For example, we may target companies that are growing rapidly and seem to have the potential to continue growing, as well as out-of-favor companies undergoing changes that may improve their earnings and growth potential. All of our research integrates fundamental and quantitative analysis, enabling us to evaluate each company’s individual merits and prospects while comparing it rigorously to a wide array of stocks. This combined analysis helps us to identify mispriced companies.

During the period, our stock selection decisions led to overweight positions, relative to the benchmark, in several sectors, particularly consumer cyclicals,

Market sector performance
These indexes provide an overview of performance in different market sectors for the
12 months ended 6/30/06.
Equities
MSCI EAFE Index (international stocks)	26.56%
MSCI Pacific Index (Asian and Australian stocks)	30.93%
MSCI Emerging Markets Free Index (emerging market stocks)	35.91%
S&P 500 Index (broad stock market)	8.63%
Bonds
Lehman Aggregate Bond Index (broad bond market)	–0.81%
Lehman Government Bond Index (U.S. Treasury and agency securities)	–1.16%
JP Morgan Global High Yield Index (global high-yield corporate bonds)	5.07%
Citigroup World Government Bond Index (global government bonds)	–0.36%

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energy, and communications services. Conversely, the fund had underweights to the health-care, consumer staples, and financials sectors. With regard to country positions relative to the benchmark, our stock selection decisions have recently produced portfolio overweights to Switzerland, Japan, South Korea, China, and Belgium, and underweights to the United Kingdom, Australia, Spain, and Germany.

Your fund’s holdings

Our stock selection decisions had the most favorable impact in the energy, consumer staples, and health-care sectors. Among energy holdings in the oil and gas industry, the portfolio had positions in two emerging-markets stocks, Petroleo Brasileiro and China Shenhua Energy, and both contributed strong results. Shares of the former, also known as Petrobras, appreciated by more than 50% during the past year as it benefited from high oil prices. The company also recently announced a $56 billion plan to nearly double production of oil and gas by 2010. Meanwhile, China Shenhua’s earnings benefited during the period as the company was able to charge higher prices in its home market, in part because China’s government is seeking to rely more on domestic resources and less on imported fuels.

The lion’s share of the portfolio’s gains in the consumer staples sector resulted from the fund’s overweight position in Japan Tobacco. Stock of this company,

Comparison of top country weightings

This chart shows how the fund’s top weightings have changed over the last six months. Weightings are shown as a percentage of net assets. Holdings will vary over time.

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the world’s third-largest cigarette maker, appreciated as its management has been able to successfully cut costs, expand overseas, and diversify its current product line to counterbalance a declining domestic tobacco market. Within the health-care sector and the portfolio overall, the top contributor was Schering AG, a German pharmaceuticals manufacturer. We built an overweight position in Schering early in the fiscal period. Schering’s shares appreciated sharply in March as the company became the target of competing acquisition bids by two other industry rivals in Germany, Merck and Bayer. Merck, a large pharmaceutical company, initiated the takeover battle, but its bid was trumped by Bayer, whose offer of 16.3 billion euros was accepted. We sold the position in Schering when its price rose as a result of the battle, because we believed that the price reflected the company’s worth.

Also adding to relative returns were overweight positions in several Japanese companies, including Mizuho Financial and Toyota Motor. Both companies have benefited from Japan’s stronger economy, and the strengthening of the yen during the period has further contributed to the appreciation of Japanese stocks. While a stronger yen is not entirely favorable to a major exporter like Toyota, the company’s production facilities in many regions of the world help to insulate the stock from fluctuating foreign exchange rates, and the company has solidified its

Top holdings

This table shows the fund’s top holdings, and the percentage of the fund’s net assets that each comprised, as of 6/30/06. The fund’s holdings will change over time.

Holding (percent of fund’s net assets)	Country	Industry
Total SA (2.6%)	France	Oil & gas
Vodafone Group PLC (2.3%)	United Kingdom	Telecommunications
UniCredito Italiano SpA (2.2%)	Italy	Banking
Roche Holding AG (2.2%)	Switzerland	Pharmaceuticals
Mizuho Financial Group, Inc. (2.0%)	Japan	Banking
Credit Suisse Group (1.9%)	Switzerland	Investment banking/brokerage
ING Groep NV (1.9%)	Netherlands	Insurance
Allianz AG (1.8%)	Germany	Insurance
Toyota Motor Corp. (1.8%)	Japan	Automotive
Royal Dutch Shell PLC Class B (1.7%)	Netherlands	Oil & gas

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leadership position in the global auto industry as the company continued to gain market share.

While our stock selections within the communications services sector had a favorable overall impact in the fiscal period, several holdings in large European telecommunications companies detracted from the fund’s results. Shares of France Telécom, as well as Vodafone Group in the United Kingdom, have traded lower in response to concerns over the competitive threat posed by smaller companies that have been aggressively competing on price. Also, a ruling by the European Commission is now compelling telecommunications companies to reduce the roaming charges billed for cross-border calls in Europe. Both of these factors contributed to a pessimistic outlook for the companies’ profit margins. Vodafone is also afflicted by uncertainty regarding its strategy. Early in 2006, Vodafone agreed to sell its Japanese unit in order to focus on becoming a more effective competitor within Europe. In our view, this may help Vodafone’s long-term strength, but markets are concerned about the company’s retreat from a global strategy. TDC, a Danish wireless company, is another stock from this sector that contributed more favorably to performance. Our analysis showed the company to be undervalued. We realized the fair value quickly after a group of private equity investors bought the company at a significant premium, and the stock is no longer in the portfolio. We continue to maintain significant holdings in the telecommunications sector because, based on our research, we believe it remains relatively undervalued, and it generates substantial free cash flow.

Also weighing on fund performance was an overweight position in Aiful, a Japanese consumer financing company. Shares of Aiful have been under pressure as increased government controls threaten profits at Japanese consumer finance companies. Proposed legislation aims to set a maximum interest rate these firms are able to charge, a move that would have a negative impact on their profit growth. In our view, the market may have overreacted to this concern, and at recent price levels the stock appears attractively valued relative to its prospects under many of the most likely scenarios that we can project for Aiful.

Please note that all holdings discussed in this report are subject to review in accordance with the fund’s investment strategy and may vary in the future.

Of special interest

Trustees approve sub-advisory agreement.

Effective July 2006, the Trustees have approved a new sub-advisory relationship for your fund. The Putnam Advisory Company (“PAC”) — an affiliate of Putnam Investment Management, LLC (“Putnam Management”), the fund’s investment manager — has been retained as an investment sub-adviser for a portion of the fund’s assets.There is no change in the contractual arrangements between Putnam Management and your

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fund. Putnam Management will remain
fully responsible for all aspects of the
management of the fund, including any
activity by PAC. PAC’s appointment also
will not change your fund’s fees, because
Putnam Management and Putnam
Investments Limited (“PIL”), the fund’s
investment sub-manager, and not the
fund, will pay PAC for its services. The
portion of the fund’s assets for which PAC
serves as sub-adviser may change from
time to time based on the direction of
Putnam Management or PIL.

The outlook for your fund

The following commentary reflects anticipated developments that could affect your fund over the next six months, as well as your management team’s plans for responding to them.

After a sustained period of gains in international markets, we believe that the global market correction that took hold in the spring was in keeping with the tendency of stock markets to pause during a rally. In our view, international markets in general remain fundamentally healthy. Japan’s recovery appears solid, and Asian markets in general are expanding vigorously, supported by stronger secular growth — or growth tied to long-term development rather than to short-term business cycles — in China. Europe is accelerating and continues to benefit from strong M&A activity. We believe the recent correction has created a fresh entry point for some of the more attractive markets — for example, Japan, where returns were negative in yen terms for the first half of 2006, even as its economic growth has accelerated and corporate profitability has improved. Select European markets also offer compelling valuation. Emerging markets may experience more challenging conditions because of higher interest rates around the world, but we continue to find many companies in the more developed markets that offer attractive valuations and strong cash flows, supported by both healthy levels of domestic economic activity and exports.

In all markets, we continue to look for high-quality companies and favor large and midsize companies because we believe they offer attractive opportunities to investors over the long term.

The views expressed in this report are exclusively those of Putnam Management. They are not meant as investment advice.

International investing involves certain risks, such as currency fluctuations, economic instability, and political developments. Additional risks may be associated with emerging-market securities, including illiquidity and volatility. The fund invests some or all of its assets in small and/or midsize companies. Such investments increase the risk of fluctuations in the value of your investment.

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Your fund’s performance

This section shows your fund’s performance for periods ended June 30, 2006, the end of its fiscal year. Performance should always be considered in light of a fund’s investment strategy. Data represents past performance. Past performance does not guarantee future results. More recent returns may be less or more than those shown. Investment return and principal value will fluctuate, and you may have a gain or a loss when you sell your shares. For the most recent month-end performance, please visit www.putnam.com or call Putnam at 1-800-225-1581. Class Y shares are generally only available to corporate and institutional clients. See the Terms and Definitions section in this report for definitions of the share classes offered by your fund.

Fund performance

Total return for periods ended 6/30/06

	Class A		Class B		Class C		Class M		Class R	Class Y
(inception dates)	(2/28/91)		(6/1/94)		(7/26/99)		(12/1/94)		(1/21/03)	(7/12/96)
	NAV	POP	NAV	CDSC	NAV	CDSC	NAV	POP	NAV	NAV
Annual average
(life of fund)	10.73%	10.34%	9.87%	9.87%	9.90%	9.90%	10.16%	9.92%	10.46%	10.91%
10 years	169.63	155.47	150.07	150.07	150.34	150.34	156.41	148.04	163.18	176.60
Annual average	10.43	9.83	9.60	9.60	9.61	9.61	9.87	9.51	10.16	10.71
5 years	43.18	35.65	37.89	35.88	38.00	38.00	39.59	35.03	41.48	45.02
Annual average	7.44	6.29	6.64	6.32	6.65	6.65	6.90	6.19	7.19	7.72
3 years	74.11	64.93	70.16	67.16	70.21	70.21	71.45	65.84	72.79	75.39
Annual average	20.30	18.15	19.39	18.68	19.40	19.40	19.69	18.37	20.00	20.60
1 year	25.70	19.08	24.77	19.77	24.77	23.77	25.12	21.07	25.42	26.05

Performance assumes reinvestment of distributions and does not account for taxes. Returns at public offering price (POP) for class A and M shares reflect a sales charge of 5.25% and 3.25%, respectively. Class B share returns reflect the applicable contingent deferred sales charge (CDSC), which is 5% in the first year, declining to 1% in the sixth year, and is eliminated thereafter. Class C shares reflect a 1% CDSC the first year that is eliminated thereafter. Class R and Y shares have no initial sales charge or CDSC. Performance for class B, C, M, R, and Y shares before their inception is derived from the historical performance of class A shares, adjusted for the applicable sales charge (or CDSC) and, except for class Y shares, the higher operating expenses for such shares.

For a portion of the period, this fund limited expenses, without which returns would have been lower.

A 2% short-term trading fee may be applied to shares exchanged or sold within 5 days of purchase. In addition, there is a 1% short-term trading fee for this fund on shares sold or exchanged between 6 and 90 days.

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Change in the value of a $10,000 investment ($9,475 after sales charge)

Cumulative total return from 6/30/96 to 6/30/06

Past performance does not indicate future results. At the end of the same time period, a $10,000 investment in the fund’s class B and class C shares would have been valued at $25,007 and $25,034, respectively, and no contingent deferred sales charges would apply. A $10,000 investment in the fund’s class M shares would have been valued at $24,804 at public offering price. A $10,000 investment in the fund’s class R and class Y shares would have been valued at $26,318 and $27,660, respectively. See first page of performance section for performance calculation method.

Comparative index returns

For periods ended 6/30/06

		Lipper International
	MSCI EAFE	Large-Cap Core Funds
	Index	category average*
Annual average
(life of fund)	6.59%	7.98%
10 years	85.86	85.04
Annual average	6.39	6.12
5 years	61.18	43.23
Annual average	10.02	7.38
3 years	90.39	76.18
Annual average	23.94	20.74
1 year	26.56	25.67

Index and Lipper results should be compared to fund performance at net asset value.

* Over the 1-, 3-, 5-, and 10-year periods ended 6/30/06, there were 208, 193, 160, and 65 funds, respectively, in this Lipper category.

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Fund price and distribution information
For the 12-month period ended 6/30/06
Distributions	Class A		Class B	Class C	Class M		Class R	Class Y
Number	1		1	1	1		1	1
Income	$0.528		$0.319	$0.328	$0.389		$0.500	$0.593
Capital gains	—		—	—	—		—	—
Total	$0.528		$0.319	$0.328	$0.389		$0.500	$0.593
Share value:	NAV	POP	NAV	NAV	NAV	POP	NAV	NAV
6/30/05	$23.39	$24.69	$22.49	$22.93	$23.00	$23.77	$23.25	$23.55
6/30/06	28.82	30.42	27.71	28.25	28.35	29.30	28.61	29.03

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Your fund’s expenses

As a mutual fund investor, you pay ongoing expenses, such as management fees, distribution fees (12b-1 fees), and other expenses. In the most recent six-month period, your fund limited these expenses; had it not done so, expenses would have been higher. Using the information below, you can estimate how these expenses affect your investment and compare them with the expenses of other funds. You may also pay one-time transaction expenses, including sales charges (loads) and redemption fees, which are not shown in this section and would have resulted in higher total expenses. For more information, see your fund’s prospectus or talk to your financial advisor.

Review your fund’s expenses

The table below shows the expenses you would have paid on a $1,000 investment in Putnam International Equity Fund from January 1, 2006, to June 30, 2006. It also shows how much a $1,000 investment would be worth at the close of the period, assuming actual returns and expenses.

	Class A	Class B	Class C	Class M	Class R	Class Y
Expenses paid per $1,000*	$ 6.52	$ 10.41	$ 10.41	$ 9.11	$ 7.81	$ 5.22
Ending value (after expenses)	$1,102.90	$1,098.70	$1,098.80	$1,100.10	$1,101.20	$1,104.20

* Expenses for each share class are calculated using the fund’s annualized expense ratio for each class, which represents the ongoing expenses as a percentage of net assets for the six months ended 6/30/06. The expense ratio may differ for each share class (see the table at the bottom of the next page). Expenses are calculated by multiplying the expense ratio by the average account value for the period; then multiplying the result by the number of days in the period; and then dividing that result by the number of days in the year. Does not reflect the effect of a non-recurring reimbursement by Putnam. If this amount had been reflected in the table above, expenses for each share class would have been lower.

Estimate the expenses you paid

To estimate the ongoing expenses you paid for the six months ended June 30, 2006, use the calculation method below. To find the value of your investment on January 1, 2006, go to www.putnam.com and log on to your account. Click on the “Transaction History” tab in your Daily Statement and enter 01/01/2006 in both the “from” and “to” fields. Alternatively, call Putnam at 1-800-225-1581.

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Compare expenses using the SEC’s method

The Securities and Exchange Commission (SEC) has established guidelines to help investors assess fund expenses. Per these guidelines, the table below shows your fund’s expenses based on a $1,000 investment, assuming a hypothetical 5% annualized return. You can use this information to compare the ongoing expenses (but not transaction expenses or total costs) of investing in the fund with those of other funds. All mutual fund shareholder reports will provide this information to help you make this comparison. Please note that you cannot use this information to estimate your actual ending account balance and expenses paid during the period.

	Class A	Class B	Class C	Class M	Class R	Class Y
Expenses paid per $1,000*	$ 6.26	$ 9.99	$ 9.99	$ 8.75	$ 7.50	$ 5.01
Ending value (after expenses)	$1,018.60	$1,014.88	$1,014.88	$1,016.12	$1,017.36	$1,019.84

* Expenses for each share class are calculated using the fund’s annualized expense ratio for each class, which represents the ongoing expenses as a percentage of net assets for the six months ended 6/30/06. The expense ratio may differ for each share class (see the table at the bottom of this page). Expenses are calculated by multiplying the expense ratio by the average account value for the period; then multiplying the result by the number of days in the period; and then dividing that result by the number of days in the year. Does not reflect the effect of a non-recurring reimbursement by Putnam. If this amount had been reflected in the table above, expenses for each share class would have been lower.

Compare expenses using industry averages

You can also compare your fund’s expenses with the average of its peer group, as defined by Lipper, an independent fund-rating agency that ranks funds relative to others that Lipper considers to have similar investment styles or objectives. The expense ratio for each share class shown below indicates how much of your fund’s net assets have been used to pay ongoing expenses during the period.

	Class A	Class B	Class C	Class M	Class R	Class Y
Your fund’s annualized
expense ratio*	1.25%	2.00%	2.00%	1.75%	1.50%	1.00%
Average annualized expense
ratio for Lipper peer group†	1.51%	2.26%	2.26%	2.01%	1.76%	1.26%

* For the fund’s most recent fiscal half year; may differ from expense ratios based on one-year data in the financial highlights. Does not reflect the effect of a non-recurring reimbursement by Putnam. If this amount had been reflected in the table above, the expense ratio for each share class would have been lower.

† Simple average of the expenses of all front-end load funds in the fund’s Lipper peer group, calculated in accordance with Lipper’s standard method for comparing fund expenses (excluding 12b-1 fees and without giving effect to any expense offset and brokerage service arrangements that may reduce fund expenses). This average reflects each fund’s expenses for its most recent fiscal year available to Lipper as of 6/30/06. To facilitate comparison, Putnam has adjusted this average to reflect the 12b-1 fees carried by each class of shares other than class Y shares, which do not incur 12b-1 fees. The peer group may include funds that are significantly smaller or larger than the fund, which may limit the comparability of the fund’s expenses to the simple average, which typically is higher than the asset-weighted average.

17

Your fund’s
portfolio turnover

Putnam funds are actively managed by teams of experts who buy and sell securities based on intensive analysis of companies, industries, economies, and markets. Portfolio turnover is a measure of how often a fund’s managers buy and sell securities for your fund. A portfolio turnover of 100%, for example, means that the managers sold and replaced securities valued at 100% of a fund’s assets within a one-year period. Funds with high turnover may be more likely to generate capital gains and dividends that must be distributed to shareholders as taxable income. High turnover may also cause a fund to pay more brokerage commissions and other transaction costs, which may detract from performance.

Turnover comparisons

Percentage of holdings that change every year

	2006	2005	2004	2003	2002
Putnam International Equity Fund	83%	75%	69%	53%*	42%
Lipper International Large-Cap
Core Funds category average	63%	60%	75%	81%	78%

Turnover data for the fund is calculated based on the fund’s fiscal-year period, which ends on June 30. Turnover data for the fund’s Lipper category is calculated based on the average of the turnover of each fund in the category for its fiscal year ended during the indicated year. Fiscal years vary across funds in the Lipper category, which may limit the comparability of the fund’s portfolio turnover rate to the Lipper average. Comparative data for 2006 is based on information available as of 6/30/06.

* Portfolio turnover excludes impact of assets received from the acquisition of Putnam Asia Pacific Fund and Putnam Emerging Markets Fund.

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Your fund’s risk

This risk comparison is designed to help you understand how your fund compares with other funds. The comparison utilizes a risk measure developed by Morningstar, an independent fund-rating agency. This risk measure is referred to as the fund’s Overall Morningstar Risk.

Your fund’s Overall Morningstar^® Risk

Your fund’s Overall Morningstar Risk is shown alongside that of the average fund in its broad asset class, as determined by Morningstar. The risk bar broadens the comparison by translating the fund’s Overall Morningstar Risk into a percentile, which is based on the fund’s ranking among all funds rated by Morningstar as of June 30, 2006. A higher Overall Morningstar Risk generally indicates that a fund’s monthly returns have varied more widely.

Morningstar determines a fund’s Overall Morningstar Risk by assessing variations in the fund’s monthly returns — with an emphasis on downside variations — over 3-, 5-, and 10-year periods, if available. Those measures are weighted and averaged to produce the fund’s Overall Morningstar Risk. The information shown is provided for the fund’s class A shares only; information for other classes may vary. Overall Morningstar Risk is based on historical data and does not indicate future results. Morningstar does not purport to measure the risk associated with a current investment in a fund, either on an absolute basis or on a relative basis. Low Overall Morningstar Risk does not mean that you cannot lose money on an investment in a fund. Copyright 2006 Morningstar, Inc. All Rights Reserved. The information contained herein (1) is proprietary to Morningstar and/or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete, or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information.

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Your fund’s management

Your fund is managed by the members of the Putnam International Core Team. Joshua Byrne and Simon Davis are Portfolio Leaders of your fund. The Portfolio Leaders coordinate the team’s management of the fund.

For a complete listing of the members of the Putnam International Core Team, including those who are not Portfolio Leaders or Portfolio Members of your fund, visit Putnam’s Individual Investor Web site at www.putnam.com.

Investment team fund ownership

The table below shows how much the fund’s current Portfolio Leaders have invested in the fund and in all Putnam mutual funds (in dollar ranges). Information shown is as of June 30, 2006, and June 30, 2005.

Trustee and Putnam employee fund ownership

As of June 30, 2006, all of the Trustees on the Board of the Putnam funds owned fund shares. The table below shows the approximate value of investments in the fund and all Putnam funds as of that date by the Trustees and Putnam employees. These amounts include investments by the Trustees’ and employees’ immediate family members and investments through retirement and deferred compensation plans.

		Total assets in
	Assets in the fund	all Putnam funds
Trustees	$ 1,378,000	$ 87,000,000
Putnam employees	$20,943,000	$421,000,000

20

Fund manager compensation

The total 2005 fund manager compensation that is attributable to your fund is approximately $3,900,000. This amount includes a portion of 2005 compensation paid by Putnam Management to the fund managers listed in this section for their portfolio management responsibilities, calculated based on the fund assets they manage taken as a percentage of the total assets they manage. The compensation amount also includes a portion of the 2005 compensation paid to the Chief Investment Officers of the team and the Group Chief Investment Officer of the fund’s broader investment category for their oversight responsibilities, calculated based on the fund assets they oversee taken as a percentage of the total assets they oversee. This amount does not include compensation of other personnel involved in research, trading, administration, systems, compliance, or fund operations; nor does it include non-compensation costs. These percentages are determined as of the fund’s fiscal period-end. For personnel who joined Putnam Management during or after 2005, the calculation reflects annualized 2005 compensation or an estimate of 2006 compensation, as applicable.

Other Putnam funds managed by the Portfolio Leaders

Joshua Byrne is also a Portfolio Leader of Putnam Europe Equity Fund.

Simon Davis is also a Portfolio Member of Putnam Europe Equity Fund.

Joshua Byrne and Simon Davis may also manage other accounts and variable trust funds advised by Putnam Management or an affiliate.

Changes in your fund’s Portfolio Leader and Portfolio Members

During the year ended June 30, 2006, Portfolio Member Mark Pollard left your fund’s management team.

21

Putnam fund ownership by Putnam’s Executive Board

The table below shows how much the members of Putnam’s Executive Board have invested in all Putnam mutual funds (in dollar ranges). Information shown is as of June 30, 2006, and June 30, 2005.

			$1 –	$10,001 –	$50,001 –	$100,001 –	$500,001 – $1,000,001
	Year	$0	$10,000	$50,000	$100,000	$500,000	$1,000,000 and over
Philippe Bibi	2006						*
Chief Technology Officer	2005						*
Joshua Brooks	2006						*
Deputy Head of Investments	2005						*
William Connolly	2006						*
Head of Retail Management	N/A
Kevin Cronin	2006						*
Head of Investments	2005						*
Charles Haldeman, Jr.	2006						*
President and CEO	2005						*
Amrit Kanwal	2006						*
Chief Financial Officer	2005						*
Steven Krichmar	2006						*
Chief of Operations	2005						*
Francis McNamara, III	2006						*
General Counsel	2005						*
Richard Robie, III	2006						*
Chief Administrative Officer	2005						*
Edward Shadek	2006						*
Deputy Head of Investments	2005						*
Sandra Whiston	2006						*
Head of Institutional Management	N/A

N/A indicates the individual was not a member of Putnam’s Executive Board as of 6/30/05.

22

Terms and definitions

Important terms

Total return shows how the value of the fund’s shares changed over time, assuming you held the shares through the entire period and reinvested all distributions in the fund.

Net asset value (NAV) is the price, or value, of one share of a mutual fund, without a sales charge. NAVs fluctuate with market conditions. NAV is calculated by dividing the net assets of each class of shares by the number of outstanding shares in the class.

Public offering price (POP) is the price of a mutual fund share plus the maximum sales charge levied at the time of purchase. POP performance figures shown here assume the 5.25% maximum sales charge for class A shares and 3.25% for class M shares.

Contingent deferred sales charge (CDSC) is generally a charge applied at the time of the redemption of class B or C shares and assumes redemption at the end of the period. Your fund’s class B CDSC declines from a 5% maximum during the first year to 1% during the sixth year. After the sixth year, the CDSC no longer applies. The CDSC for class C shares is 1% for one year after purchase.

Share classes

Class A shares are generally subject to an initial sales charge and no CDSC (except on certain redemptions of shares bought without an initial sales charge).

Class B shares are not subject to an initial sales charge. They may be subject to a CDSC.

Class C shares are not subject to an initial sales charge and are subject to a CDSC only if the shares are redeemed during the first year.

Class M shares have a lower initial sales charge and a higher 12b-1 fee than class A shares and no CDSC (except on certain redemptions of shares bought without an initial sales charge).

Class R shares are not subject to an initial sales charge or CDSC and are available only to certain defined contribution plans.

Class Y shares are not subject to an initial sales charge or CDSC, and carry no 12b-1 fee. They are only available to eligible purchasers, including eligible defined contribution plans or corporate IRAs.

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Comparative indexes

Citigroup World Government Bond Index is an unmanaged index of global investment-grade fixed-income securities.

JP Morgan Global High Yield Index is an unmanaged index of global high-yield fixed-income securities.

Lehman Aggregate Bond Index is an unmanaged index of U.S. investment-grade fixed-income securities.

Lehman Government Bond Index is an unmanaged index of U.S. Treasury and agency securities.

Morgan Stanley Capital International (MSCI) EAFE Index is an unmanaged index of equity securities from developed countries in Western Europe, the Far East, and Australasia.

Morgan Stanley Capital International (MSCI) Emerging Markets Free Index is an unmanaged index of equity securities from emerging markets available to non-U.S. investors.

Morgan Stanley Capital International (MSCI) Pacific Index is an unmanaged index of equity securities from Australia and developed countries in Asia.

S&P 500 Index is an unmanaged index of common stock performance.

Indexes assume reinvestment of all distributions and do not account for fees. Securities and performance of a fund and an index will differ. You cannot invest directly in an index.

Lipper is a third-party industry-ranking entity that ranks mutual funds. Its rankings do not reflect sales charges. Lipper rankings are based on total return at net asset value relative to other funds that have similar current investment styles or objectives as determined by Lipper. Lipper may change a fund’s category assignment at its discretion. Lipper category averages reflect performance trends for funds within a category.

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Trustee approval of
management contract

General conclusions

The Board of Trustees of the Putnam funds oversees the management of each fund and, as required by law, determines annually whether to approve the continuance of your fund’s management contract with Putnam Management and the sub-management contract between Putnam Management’s affiliate, Putnam Investments Limited (“PIL”), and Putnam Management. In this regard, the Board of Trustees, with the assistance of its Contract Committee consisting solely of Trustees who are not “interested persons” (as such term is defined in the Investment Company Act of 1940, as amended) of the Putnam funds (the “Independent Trustees”), requests and evaluates all information it deems reasonably necessary under the circumstances. Over the course of several months ending in June 2006, the Contract Committee met four times to consider the information provided by Putnam Management and other information developed with the assistance of the Board’s independent counsel and independent staff. The Contract Committee reviewed and discussed key aspects of this information with all of the Independent Trustees. Upon completion of this review, the Contract Committee recommended, and the Independent Trustees approved, the continuance of your fund’s management contract and sub-management contract, effective July 1, 2006. (Because PIL is an affiliate of Putnam Management and Putnam Management remains fully responsible for all services provided by PIL, the Trustees have not evaluated PIL as a separate entity, and all subsequent references to Putnam Management below include reference to PIL as necessary or appropriate in the context.)

This approval was based on the following conclusions:

* That the fee schedule in effect for your fund represents reasonable compensation in light of the nature and quality of the services being provided to the fund, the fees paid by competitive funds and the costs incurred by Putnam Management in providing such services, and

* That such fee schedule represents an appropriate sharing between fund shareholders and Putnam Management of such economies of scale as may exist in the management of the fund at current asset levels.

These conclusions were based on a comprehensive consideration of all information provided to the Trustees and were not the result of any single factor. Some of the factors that figured particularly in the Trustees’ deliberations and how the Trustees considered these factors are described below, although individual Trustees may have evaluated the information presented differently, giving different weights to various factors. It is also important to recognize that the fee arrangements for your fund and the other Putnam funds are the result of many years of review and discussion between the Independent Trustees and Putnam Management, that certain aspects of such arrangements may receive greater scrutiny in some years than others, and that the Trustees’ conclusions may be based, in part, on their consideration of these same arrangements in prior years.

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Management fee schedules and categories; total expenses

The Trustees reviewed the management fee schedules in effect for all Putnam funds, including fee levels and breakpoints, and the assignment of funds to particular fee categories. In reviewing fees and expenses, the Trustees generally focused their attention on material changes in circumstances — for example, changes in a fund’s size or investment style, changes in Putnam Management’s operating costs, or changes in competitive practices in the mutual fund industry — that suggest that consideration of fee changes might be warranted. The Trustees concluded that the circumstances did not warrant changes to the management fee structure of your fund, which had been carefully developed over the years, re-examined on many occasions and adjusted where appropriate. The Trustees focused on two areas of particular interest, as discussed further below:

* Competitiveness. The Trustees reviewed comparative fee and expense information for competitive funds, which indicated that, in a custom peer group of competitive funds selected by Lipper Inc., your fund ranked in the 4th percentile in management fees and in the 1st percentile in total expenses (less any applicable 12b-1 fees) as of December 31, 2005 (the first percentile being the least expensive funds and the 100th percentile being the most expensive funds). The Trustees noted that expense ratios for a number of Putnam funds, which show the percentage of fund assets used to pay for management and administrative services, distribution (12b-1) fees and other expenses, had been increasing recently as a result of declining net assets and the natural operation of fee breakpoints.

The Trustees noted that the expense ratio increases described above were currently being controlled by expense limitations implemented in January 2004 and which Putnam Management, in consultation with the Contract Committee, has committed to maintain at least through 2007. These expense limitations give effect to a commitment by Putnam Management that the expense ratio of each open-end fund would be no higher than the average expense ratio of the competitive funds included in the fund’s relevant Lipper universe (exclusive of any applicable 12b-1 charges in each case). The Trustees observed that this commitment to limit fund expenses has served shareholders well since its inception. In order to ensure that the expenses of the Putnam funds continue to meet evolving competitive standards, the Trustees requested, and Putnam Management agreed, to implement an additional expense limitation for certain funds for the twelve months beginning January 1, 2007 equal to the average expense ratio (exclusive of 12b-1 charges) of a custom peer group of competitive funds selected by Lipper based on the size of the fund. This additional expense limitation will be applied to those open-end funds that had above-average expense ratios (exclusive of 12b-1 charges) based on the Lipper custom peer group data for the period ended December 31, 2005. This additional expense limitation will not be applied to your fund.

26

* Economies of scale. Your fund currently has the benefit of breakpoints in its management fee that provide shareholders with significant economies of scale, which means that the effective management fee rate of a fund (as a percentage of fund assets) declines as a fund grows in size and crosses specified asset thresholds. Conversely, as a fund shrinks in size — as has been the case for many Putnam funds in recent years — these breakpoints result in increasing fee levels. In recent years, the Trustees have examined the operation of the existing breakpoint structure during periods of both growth and decline in asset levels. The Trustees concluded that the fee schedules in effect for the funds represented an appropriate sharing of economies of scale at current asset levels. In reaching this conclusion, the Trustees considered the Contract Committee’s stated intent to continue to work with Putnam Management to plan for an eventual resumption in the growth of assets, including a study of potential economies that might be produced under various growth assumptions.

In connection with their review of the management fees and total expenses of the Putnam funds, the Trustees also reviewed the costs of the services to be provided and profits to be realized by Putnam Management and its affiliates from the relationship with the funds. This information included trends in revenues, expenses and profitability of Putnam Management and its affiliates relating to the investment management and distribution services provided to the funds. In this regard, the Trustees also reviewed an analysis of Putnam Management’s revenues, expenses and profitability with respect to the funds’ management contracts, allocated on a fund-by-fund basis. Because many of the costs incurred by Putnam Management in managing the funds are not readily identifiable to particular funds, the Trustees observed that the methodology for allocating costs is an important factor in evaluating Putnam Management’s costs and profitability, both as to the Putnam funds in the aggregate and as to individual funds. The Trustees reviewed Putnam Management’s cost allocation methodology with the assistance of independent consultants and concluded that this methodology was reasonable and well-considered.

Investment performance

The quality of the investment process provided by Putnam Management represented a major factor in the Trustees’ evaluation of the quality of services provided by Putnam Management under your fund’s management contract. The Trustees were assisted in their review of the Putnam funds’ investment process and performance by the work of the Investment Process Committee of the Trustees and the Investment Oversight Committee of the Trustees, which meet on a regular monthly basis with the funds’ portfolio teams throughout the year. The Trustees concluded that Putnam Management generally provides a high-quality investment process — as measured by the experience and skills of the individuals assigned to the management of fund portfolios, the resources made available to such personnel, and in general the ability of Putnam Management to attract and retain high-quality personnel — but also recognize that this does not guarantee favorable investment results for every fund in every time period. The Trustees considered the investment performance of each fund over multiple time periods

27

and considered information comparing each fund’s performance with various benchmarks and with the performance of competitive funds.

The Trustees noted the satisfactory investment performance of many Putnam funds. They also noted the disappointing investment performance of certain funds in recent years and discussed with senior management of Putnam Management the factors contributing to such underperfor-mance and actions being taken to improve performance. The Trustees recognized that, in recent years, Putnam Management has made significant changes in its investment personnel and processes and in the fund product line to address areas of underperformance. In particular, they noted the important contributions of Putnam Management’s leadership in attracting, retaining and supporting high-quality investment professionals and in systematically implementing an investment process that seeks to merge the best features of fundamental and quantitative analysis. The Trustees indicated their intention to continue to monitor performance trends to assess the effectiveness of these changes and to evaluate whether additional changes to address areas of underperformance are warranted.

In the case of your fund, the Trustees considered that your fund’s class A share cumulative total return performance at net asset value was in the following percentiles of its Lipper Inc. peer group (Lipper International Large-Cap Core Funds) for the one-, three- and five-year periods ended March 31, 2006 (the first percentile being the best performing funds and the 100th percentile being the worst performing funds):

One-year period	Three-year period	Five-year period
57th	68th	51st

(Because of the passage of time, these performance results may differ from the performance results for more recent periods shown elsewhere in this report. Over the one-, three- and five-year periods ended March 31, 2006, there were 211, 194, and 150 funds, respectively, in your fund’s Lipper peer group.* Past performance is no guarantee of future performance.)

As a general matter, the Trustees concluded that cooperative efforts between the Trustees and Putnam Management represent the most effective way to address investment performance problems. The Trustees noted that investors in the Putnam funds have, in effect, placed their trust in the Putnam organization, under the oversight of the funds’ Trustees, to make appropriate decisions regarding the management of the funds. Based on the responsiveness of Putnam Management in the recent past to Trustee concerns about investment performance, the Trustees concluded that it is preferable to seek change within Putnam Management to address performance shortcomings. In the Trustees’ view, the alternative of terminating a

* The percentile rankings for your fund’s class A share annualized total return performance in the Lipper International Large-Cap Core Funds category for the one-, five- and ten-year periods ended June 30, 2006 , were 58%, 51%, and 8%, respectively. Over the one-, five- and ten-year periods ended June 30, 2006, the fund ranked 121st out of 208, 81st out of 160, and 5th out of 65 funds, respectively. Note that this more recent information was not available when the Trustees approved the continuance of your fund’s management contract.

28

management contract and engaging a new investment adviser for an underperforming fund would entail significant disruptions and would not provide any greater assurance of improved investment performance.

Brokerage and soft-dollar allocations; other benefits

The Trustees considered various potential benefits that Putnam Management may receive in connection with the services it provides under the management contract with your fund. These include benefits related to brokerage and soft-dollar allocations, whereby a portion of the commissions paid by a fund for brokerage may be used to acquire research services that may be useful to Putnam Management in managing the assets of the fund and of other clients. The Trustees indicated their continued intent to monitor the potential benefits associated with the allocation of fund brokerage to ensure that the principle of seeking “best price and execution” remains paramount in the portfolio trading process.

The Trustees’ annual review of your fund’s management contract also included the review of its distributor’s contract and distribution plan with Putnam Retail Management Limited Partnership and the custodian agreement and investor servicing agreement with Putnam Fiduciary Trust Company, all of which provide benefits to affiliates of Putnam Management.

Comparison of retail and institutional fee schedules

The information examined by the Trustees as part of their annual contract review has included for many years information regarding fees charged by Putnam Management and its affiliates to institutional clients such as defined benefit pension plans, college endowments, etc. This information included comparison of such fees with fees charged to the funds, as well as a detailed assessment of the differences in the services provided to these two types of clients. The Trustees observed, in this regard, that the differences in fee rates between institutional clients and the mutual funds are by no means uniform when examined by individual asset sectors, suggesting that differences in the pricing of investment management services to these types of clients reflect to a substantial degree historical competitive forces operating in separate market places. The Trustees considered the fact that fee rates across all asset sectors are higher on average for mutual funds than for institutional clients, as well as the differences between the services that Putnam Management provides to the Putnam funds and those that it provides to institutional clients of the firm, but did not rely on such comparisons to any significant extent in concluding that the management fees paid by your fund are reasonable.

29

Other information
for shareholders

Putnam’s policy on confidentiality

In order to conduct business with our shareholders, we must obtain certain personal information such as account holders’ addresses, telephone numbers, Social Security numbers, and the names of their financial advisors. We use this information to assign an account number and to help us maintain accurate records of transactions and account balances. It is our policy to protect the confidentiality of your information, whether or not you currently own shares of our funds, and in particular, not to sell information about you or your accounts to outside marketing firms. We have safeguards in place designed to prevent unauthorized access to our computer systems and procedures to protect personal information from unauthorized use. Under certain circumstances, we share this information with outside vendors who provide services to us, such as mailing and proxy solicitation. In those cases, the service providers enter into confidentiality agreements with us, and we provide only the information necessary to process transactions and perform other services related to your account. We may also share this information with our Putnam affiliates to service your account or provide you with information about other Putnam products or services. It is also our policy to share account information with your financial advisor, if you’ve listed one on your Putnam account. If you would like clarification about our confidentiality policies or have any questions or concerns, please don’t hesitate to contact us at 1-800-225-1581, Monday through Friday, 8:30 a.m. to 7:00 p.m., or Saturdays from 9:00 a.m. to 5:00 p.m. Eastern Time.

Proxy voting

Putnam is committed to managing our mutual funds in the best interests of our shareholders. The Putnam funds’ proxy voting guidelines and procedures, as well as information regarding how your fund voted proxies relating to portfolio securities during the 12-month period ended June 30, 2006, are available on the Putnam Individual Investor Web site, www.putnam.com/individual, and on the SEC’s Web site, www.sec.gov. If you have questions about finding forms on the SEC’s Web site, you may call the SEC at 1-800-SEC-0330. You may also obtain the Putnam funds’ proxy voting guidelines and procedures at no charge by calling Putnam’s Shareholder Services at 1-800-225-1581.

Fund portfolio holdings

The fund will file a complete schedule of its portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-Q. Shareholders may obtain the fund’s Forms N-Q on the SEC’s Web site at www.sec.gov. In addition, the fund’s Forms N-Q may be reviewed and copied at the SEC’s Public Reference Room in Washington, D.C. You may call the SEC at 1-800-SEC-0330 for information about the SEC’s Web site or the operation of the Public Reference Room.

30

Financial statements

A guide to financial statements

These sections of the report, as well as the accompanying Notes, preceded by the Report of Independent Registered Public Accounting Firm, constitute the fund’s financial statements.

The fund’s portfolio lists all the fund’s investments and their values as of the last day of the reporting period. Holdings are organized by asset type and industry sector, country, or state to show areas of concentration and diversification.

Statement of assets and liabilities shows how the fund’s net assets and share price are determined. All investment and noninvestment assets are added together. Any unpaid expenses and other liabilities are subtracted from this total. The result is divided by the number of shares to determine the net asset value per share, which is calculated separately for each class of shares. (For funds with preferred shares, the amount subtracted from total assets includes the liquidation preference of preferred shares.)

Statement of operations shows the fund’s net investment gain or loss. This is done by first adding up all the fund’s earnings — from dividends and interest income — and subtracting its operating expenses to determine net investment income (or loss). Then, any net gain or loss the fund realized on the sales of its holdings — as well as any unrealized gains or losses over the period — is added to or subtracted from the net investment result to determine the fund’s net gain or loss for the fiscal year.

Statement of changes in net assets shows how the fund’s net assets were affected by the fund’s net investment gain or loss, by distributions to shareholders, and by changes in the number of the fund’s shares. It lists distributions and their sources (net investment income or realized capital gains) over the current reporting period and the most recent fiscal year-end. The distributions listed here may not match the sources listed in the Statement of operations because the distributions are determined on a tax basis and may be paid in a different period from the one in which they were earned.

Financial highlights provide an overview of the fund’s investment results, per-share distributions, expense ratios, net investment income ratios, and portfolio turnover in one summary table, reflecting the five most recent reporting periods. In a semiannual report, the highlight table also includes the current reporting period.

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Report of Independent Registered Public Accounting Firm

To the Trustees and Shareholders of
Putnam International Equity Fund:

In our opinion, the accompanying statement of assets and liabilities, including the fund’s portfolio, and the related statements of operations and of changes in net assets and the financial highlights present fairly, in all material respects, the financial position of Putnam International Equity Fund (the “fund”) at June 30, 2006, and the results of its operations, the changes in its net assets and the financial highlights for each of the periods indicated, in conformity with accounting principles generally accepted in the United States of America. These financial statements and financial highlights (hereafter referred to as “financial statements”) are the responsibility of the fund’s management; our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits of these financial statements in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits, which included confirmation of investments owned at June 30, 2006, by correspondence with the custodian and brokers, provide a reasonable basis for our opinion.

PricewaterhouseCoopers LLP
Boston, Massachusetts
August 10, 2006

32

The fund’s portfolio 6/30/06
COMMON STOCKS (98.8%)*
	Shares		Value
Australia (1.8%)
Commonwealth Bank of Australia	75,864	$	2,502,246
Macquarie Bank, Ltd.	1,033,262		52,950,854
Macquarie Infrastructure Group	12,591,726		31,422,300
Macquerie Infrastructure Group 144A	1,067,033		2,662,751
Mayne Pharma, Ltd. †	1,488,783		2,874,870
National Australia Bank, Ltd.	280,097		7,314,266
Promina Group, Ltd.	656,269		2,739,250
Rio Tinto, Ltd.	120,556		6,965,974
SP AusNet	72,839		68,163
Spark Infrastructure Group	316,812		265,885
Telstra Corp., Ltd.	23,623		64,565
Woolworths, Ltd.	206,566		3,091,344
			112,922,468
Austria (0.1%)
Oesterreichische Post AG †	84,000		2,547,386
Oesterreichische Post AG 144A †	45,299		1,373,738
			3,921,124
Belgium (3.0%)
InBev NV	1,233,984		60,502,822
KBC Groupe SA	813,601		87,271,847
Mobistar SA	553,506		43,910,143
			191,684,812
Brazil (1.1%)
Banco Bradesco SA (Preference)	29,310		917,377
Companhia Vale do Rio Doce (CVRD) ADR	25,683		617,419
EDP — Energias do Brasil SA	43,700		545,492
Lupatech SA †	33,100		324,420
Lupatech SA 144A †	39,100		383,227
Petroleo Brasileiro SA ADR	758,145		67,709,930
Usinas Siderurgicas de Minas Gerais(Usiminas) (Preference)	48,095		1,726,573
			72,224,438
Canada (1.0%)
Alcan Aluminum, Ltd.	17,500		823,057
Algoma Steel, Inc.	14,100		449,582
Aliant, Inc.	10,700		319,229
Bank of Montreal	20,990		1,133,890
Bank of Nova Scotia	7,900		314,209
CAE, Inc.	39,300		300,459
Canadian Imperial Bank of Commerce	18,734		1,258,875
Canadian National Railway Co.	28,206		1,237,025
Canadian Natural Resources, Ltd.	321,950		17,872,598
Canadian Pacific Railway, Ltd.	4,500		230,343

33

COMMON STOCKS (98.8%)* continued
	Shares		Value
Canada continued
EnCana Corp.	13,800	$	729,595
Goldcorp, Inc. (New York Exchange)	20,400		617,431
Husky Energy, Inc.	7,380		465,050
Imperial Oil, Ltd. (Toronto Exchange)	25,527		936,311
ING Canada, Inc.	10,174		517,027
IPSCO, Inc.	6,126		588,852
Magna International, Inc. Class A	5,319		381,008
Manulife Financial Corp.	57,172		1,818,829
Methanex Corp.	35,262		746,281
National Bank of Canada	17,942		919,854
Petro-Canada	28,466		1,355,963
Power Financial Corp.	26,206		738,473
RONA, Inc. †	13,600		245,260
Royal Bank of Canada	15,756		642,258
Suncor Energy, Inc.	3,200		260,018
Talisman Energy, Inc.	73,678		1,290,922
Teck Comico, Ltd. Class B	58,605		3,530,638
Telus Corp.	514,526		20,848,531
TransAlta Corp.	8,200		170,077
TransCanada Corp.	13,500		386,738
TSX Group, Inc.	12,600		507,717
			61,636,100
Chile (—%)
Inversiones Aguas Metropolitanas SA	360,377		364,051
China (0.1%)
Air China, Ltd.	2,280,000		954,073
China Petroleum & Chemical Corp.	2,034,000		1,165,398
China Shenhua Energy Co., Ltd.	1,237,500		2,286,444
China Shipping Development Co.	1,012,000		729,679
FU JI Food and Catering Services Holdings, Ltd.	94,000		154,918
			5,290,512
Denmark (—%)
Genmab A/S †	7,125		229,646
Egypt (—%)
Orascom Construction Industries (OCI)	30,001		915,057
Finland (—%)
Nokia OYJ	127,293		2,597,396
France (10.5%)
Air Liquide	15,758		3,068,328
Alcatel SA	142,054		1,801,631
Alstrom †	13,187		1,204,617
Arkema †	4,688		182,865
Axa SA	193,273		6,340,574

34

COMMON STOCKS (98.8%)* continued
	Shares		Value
France continued
BNP Paribas SA	1,012,470	$	96,889,051
Business Objects SA †	79,607		2,170,915
Christian Dior SA	32,508		3,185,687
France Telecom SA	3,026,224		65,038,350
France Telecom SA 144A	147,848		3,177,488
Groupe Danone	22,205		2,820,456
LVMH Moet Hennessy Louis Vuitton SA	35,577		3,529,651
Renault SA	907,615		97,472,405
Sanofi-Synthelabo SA	33,363		3,254,546
Schneider Electric SA	349,560		36,423,365
Societe Generale	685,079		100,725,453
Technip SA	87,985		4,870,766
Total SA	2,528,246		166,305,051
Veolia Environnement	1,321,054		68,251,178
			666,712,377
Germany (5.3%)
Adidas-Salomon AG	737,556		35,502,645
Allianz AG	739,310		116,685,907
BASF AG	1,282,094		102,840,721
Bayerische Motoren Werke (BMW) AG	35,200		1,756,925
Deutsche Bank AG	55,500		6,241,356
Deutsche Post AG	88,150		2,367,822
Henkel KGaA	55,995		5,823,099
Henkel KGaA (Preference)	470,784		53,803,604
SAP AG	14,424		3,040,935
Schwarz Pharma AG	26,716		2,395,047
Siemens AG	40,604		3,532,626
ThyssenKrupp AG	64,947		2,217,028
			336,207,715
Greece (1.2%)
Alpha Bank AE	342,308		8,525,242
Hellenic Telecommunication Organization (OTE) SA †	1,442,172		31,750,527
Hellenic Telecommunication Organization (OTE) SA 144A	18,500		407,292
National Bank of Greece SA	710,899		28,066,349
Postal Savings Bank †	483,553		9,903,925
Postal Savings Bank 144A †	69,726		1,428,098
			80,081,433
Hong Kong (0.6%)
BOC Hong Kong Holdings, Ltd.	1,954,000		3,824,121
Cheung Kong Infrastructure Holdings, Ltd.	103,000		297,726
China Netcom Group Corp. (Hong Kong), Ltd.	543,500		951,704
China Resources Power Holdings Co.	850,000		711,370
Esprit Holdings, Ltd.	3,363,500		27,456,436
Great Eagle Holdings, Ltd.	396,000		1,356,252
Hang Lung Properties, Ltd.	525,000		939,588
Hong Kong and China Gas Co., Ltd.	127,000		278,799

35

COMMON STOCKS (98.8%)* continued
	Shares		Value
Hong Kong continued
Hong Kong Electric Holdings, Ltd.	178,000	$	805,580
Hutchinson Telecommunications International, Ltd. †	89,000		143,240
Orient Overseas International, Ltd.	69,000		250,087
			37,014,903
Hungary (0.3%)
MOL Magyar Olaj- es Gazipari Rt.	208,814		21,458,720
India (—%)
GVK Power & Infrastructure, ltd. †	1,437		5,132
National Thermal Power Corp., Ltd.	27,640		66,593
			71,725
Indonesia (—%)
Bank Rakyat Indonesia	851,000		376,711
PT Astra International, Inc.	367,000		386,337
			763,048
Ireland (1.8%)
Bank of Ireland PLC	1,975,605		35,235,063
CRH PLC	2,436,674		79,190,614
			114,425,677
Israel (—%)
Bank Hapoalim BM	51,672		220,119
Teva Pharmaceutical Industries, Ltd. ADR	55,288		1,746,548
			1,966,667
Italy (4.2%)
Enel SpA	443,327		3,820,189
Fastweb	37,797		1,638,649
IntesaBCI SpA	9,108,754		53,336,582
Mediaset SpA	5,166,607		60,770,665
Saipem SpA	324,414		7,366,196
Saras SpA †	75,380		482,830
UniCredito Italiano SpA	17,708,357		139,123,626
			266,538,737
Japan (26.5%)
Aeon Co., Ltd.	1,604,200		35,227,839
Aiful Corp.	776,600		41,513,788
Asahi Glass Co., Ltd.	68,000		863,237
Asahi Kasei Corp.	6,747,000		44,094,567
Astellas Pharma, Inc.	221,300		8,131,759
Canon, Inc.	1,339,392		65,739,187
Chiyoda Corp.	1,076,000		22,028,346
Chubu Electric Power, Inc.	13,900		375,774
Credit Saison Co., Ltd.	920,100		43,630,289
Dai Nippon Printing Co., Ltd.	3,965,000		61,400,262
Daiichi Sankyo Co., Ltd.	1,722,600		47,473,228

36

COMMON STOCKS (98.8%)* continued
	Shares		Value
Japan continued
Daito Trust Construction Co., Ltd.	1,250,000	$	69,335,083
Dowa Mining Co., Ltd.	45,000		398,425
East Japan Railway Co.	12,874		95,738,408
Electric Power Development Co.	1,086,200		41,433,351
Fanuc, Ltd.	440,400		39,609,029
Fuji Television Network, Inc.	1,070		2,377,778
Honda Motor Co., Ltd.	44,000		1,397,375
Hoya Corp.	140,300		4,995,809
Japan Tobacco, Inc.	22,951		83,731,995
JSR Corp.	88,200		2,230,079
Kansai Electric Power, Inc.	37,800		846,614
KDDI Corp.	161		990,227
Komatsu, Ltd.	660,000		13,136,483
Konica Corp.	3,504,000		44,298,163
Kubota Corp.	2,148,000		20,390,026
Kyushu Electric Power Co., Inc.	12,300		286,247
Lawson, Inc.	1,036,600		37,818,215
Matsushita Electric Industrial Co., Ltd.	4,551,000		96,156,299
Mitsubishi Corp.	2,687,600		53,728,486
Mitsubishi UFJ Financial Group, Inc.	965		13,508,311
Mitsui & Co., Ltd.	161,000		2,276,255
Mitsui Fudoscan Co., Ltd.	1,812,000		39,394,751
Mitsui O.S.K Lines, Ltd.	322,000		2,191,741
Mizuho Financial Group, Inc.	14,725		124,833,989
Nidec Corp.	14,800		1,061,767
Nippon Mining Holdings, Inc.	1,780,500		15,001,063
Nippon Steel Corp.	1,246,000		4,720,192
Nippon Telegraph & Telephone (NTT) Corp.	311		1,526,430
Nissan Motor Co., Ltd.	2,425,000		26,520,122
Nomura Securities Co., Ltd.	441,900		8,292,874
NSK, Ltd.	23,000		190,962
NTT DoCoMo, Inc.	1,120		1,646,194
Obayashi Corp.	97,000		667,883
Omron Corp.	1,988,000		50,700,087
Ono Pharmaceutical Co., Ltd.	519,500		25,315,967
Orix Corp.	30,440		7,443,552
Osaka Gas Co., Ltd.	77,000		247,909
Rohm Co., Ltd.	421,500		37,724,803
Sankyo Co., Ltd.	628,600		39,981,820
Shimizu Corp.	4,471,000		25,073,587
Shin-Etsu Chemical Co.	40,700		2,214,821
SMC Corp.	19,800		2,804,567
Sony Corp.	32,600		1,440,332
Sumitomo Mitsui Banking Corp.	216,000		2,362,205
Suzuki Motor Corp.	2,547,600		55,164,567
Takeda Pharmaceutical Co., Ltd.	29,300		1,825,162
Terumo Corp.	1,009,600		33,741,662
Tohoku Electric Power Co., Inc.	16,800		368,924
Tokyo Electric Power Co.	59,700		1,650,499

37

COMMON STOCKS (98.8%)* continued
	Shares		Value
Japan continued
Tokyo Gas Co., Ltd.	6,214,000	$	29,303,115
TonenGeneral Sekiyu KK	3,067,000		31,555,486
Toto, Ltd.	34,000		325,424
Toyo Suisan Kaisha, Ltd.	169,000		2,649,589
Toyota Motor Corp.	2,219,900		116,335,967
			1,689,438,947
Malaysia (—%)
Digi.com Berhad †	76,400		226,786
Mexico (—%)
Axtel SA de CV †	283,424		527,487
Axtel SA de CV 144A †	120,100		223,521
Wal-Mart de Mexico SA de CV Ser. V	325,100		913,340
			1,664,348
Netherlands (9.2%)
ABN AMRO Holding NV	3,611,016		98,750,870
Endemol NV	213,272		3,577,407
European Aeronautic Defense and Space Co.	1,326,277		38,084,190
European Aeronautic Defense and Space Co. 144A	389,980		11,198,319
ING Groep NV	3,040,519		119,456,838
Koninklijke (Royal) KPN NV	7,297,348		82,007,706
Koninklijke (Royal) KPN NV 144A	306,769		3,447,475
Royal Dutch Shell PLC Class A	3,293,546		110,744,002
Royal Dutch Shell PLC Class B	3,185,163		111,385,988
Royal Numico NV	71,135		3,191,299
SBM Offshore NV	213,997		5,701,723
			587,545,817
New Zealand (—%)
Telecom Corp. of New Zealand, Ltd.	167,408		412,493
Norway (1.1%)
DnB Holdings ASA	230,355		2,860,782
Norsk Hydro ASA	2,436,170		64,621,972
Schibsted ASA	72,699		1,940,105
Statoil ASA	33,024		937,051
			70,359,910
Philippines (—%)
First Philippine Holdings Corp.	120,230		101,871
Globe Telecom, Inc.	23,930		419,034
			520,905
Russia (0.3%)
Lukoil	14,822		1,239,119
Mobile Telesystems ADR	28,500		839,040
OAO Gazprom	1,393,581		14,632,601
Sberbank RF	376		641,080
			17,351,840

38

COMMON STOCKS (98.8%)* continued
	Shares		Value
Singapore (2.4%)
Ascendas Real Estate Investment Trust (R)	1,051,000	$	1,276,357
Chartered Semiconductor Manufacturing, Ltd. †	45,356,000		38,729,032
SembCorp Industries, Ltd.	147,580		302,441
Singapore Airlines, Ltd.	3,681,000		29,569,070
Singapore Telecommunications, Ltd.	11,170,000		17,945,478
StarHub, Ltd.	648,000		934,497
StarHub, Ltd. 144A	1,457,000		2,101,176
United Overseas Bank, Ltd.	6,290,000		62,064,516
			152,922,567
South Africa (0.1%)
Aveng, Ltd.	262,817		791,029
Gold Fields, Ltd.	4,266		96,972
Gold Fields, Ltd. ADR	30,851		706,488
Impala Platinum Holdings, Ltd.	3,315		613,917
Imperial Holdings, Ltd. †	26,474		501,493
Metropolitan Holdings, Ltd.	321,977		533,112
Network Healthcare Holdings, Ltd. †	488,996		658,014
Reunert, Ltd.	80,593		735,059
Sasol, Ltd.	26,078		1,006,279
			5,642,363
South Korea (1.9%)
Daegu Bank	52,670		944,106
Daewoo Shipbuilding & Marine Engineering Co., Ltd. 144A	21,530		633,369
GS Holdings Corp.	15,930		500,542
Hynix Semiconductor, Inc. †	916,410		29,712,787
Hynix Semiconductor, Inc. GDR 144A †	172,100		5,390,172
Kookmin Bank	7,860		646,436
Korean Air Co., Ltd.	24,480		903,416
LG Electronics, Inc.	11,810		716,022
LG Engineering & Construction, Ltd.	7,360		476,491
Macquarie Korea Infrastructure GDR 144A †	20,500		144,320
MegaStudy Co., Ltd.	4,708		459,184
POSCO	170,683		45,802,218
POSCO ADR	4,300		287,670
Samsung Electronics Co., Ltd.	2,162		1,374,616
Shinhan Financial Group Co., Ltd.	643,400		30,189,055
SK Corp.	18,530		1,191,828
			119,372,232
Spain (2.0%)
Autopistas Concesionaria Espanola SA	101,474		2,375,439
Banco Bilbao Vizcaya Argentaria SA	503,644		10,354,054
Grifols SA †	326,917		2,687,505
Grifols SA 144A †	93,530		768,887
Iberdrola SA	3,194,399		109,983,174
Repsol YPF SA	70,469		2,017,218
			128,186,277

39

COMMON STOCKS (98.8%)* continued
	Shares		Value
Sweden (1.8%)
Hennes & Mauritz AB Class B	1,044,229	$	40,456,007
Skanska AB Class B	82,000		1,263,921
SKF AB Class B	1,630,417		25,696,716
Telefonaktiebolaget LM Ericsson AB Class B	14,793,539		48,891,358
Volvo AB Class B	29,400		1,445,219
			117,753,221
Switzerland (10.7%)
ABB, Ltd.	140,583		1,825,157
Arpida, Ltd. †	11,437		211,987
Arpida, Ltd. 144A †	32,180		596,461
Basilea Pharmaceutica AG †	1,547		224,212
Credit Suisse Group	2,199,299		122,831,756
Holcim, Ltd.	318,155		24,341,572
Julius Baer Holding, Ltd. Class B	572,156		49,614,573
Nestle SA	233,796		73,305,841
Nobel Biocare Holding AG	260,198		61,666,097
Novartis AG	418,102		22,600,108
Roche Holding AG	834,993		137,790,549
Serono SA	18,319		12,631,988
Speedel Holding AG †	8,462		1,105,512
STMicroelectronics NV	2,163,951		34,831,637
Straumann Holding AG	3,047		775,620
Swatch Group AG (The)	153,263		5,343,619
Swatch Group AG (The) Class B	179,441		30,256,035
Synthes, Inc.	7,449		897,140
Xstrata PLC (London Exchange)	426,604		16,172,835
Xstrata PLC 144A	144,900		5,493,253
Zurich Financial Services AG	350,264		76,647,956
			679,163,908
Taiwan (0.6%)
China Steel Corp.	902,000		894,421
Far EasTone Telecommunications Co., Ltd.	685,000		766,001
Hon Hai Precision Industry Co., Ltd.	85,000		525,145
King Yuan Electronics Co., Ltd.	488,000		410,033
Lite-On Technology Corp.	11,817,000		17,503,557
Quanta Computer, Inc.	727,000		1,163,308
Siliconware Precision Industries Co.	478,833		588,705
Sinopac Holdings Co.	784,000		395,972
Taiwan Semiconductor Manufacturing Co., Ltd.	419,202		756,252
United Microelectronics Corp.	24,907,518		14,926,660
			37,930,054

40

COMMON STOCKS (98.8%)* continued
	Shares		Value
Thailand (—%)
Italian-Thai Development PLC NVDR (Non Voting
Depository Receipt)	3,707,700	$	490,861
Krung Thai Bank PCL NVDR (Non Voting Depository Receipt)	404,300		107,050
Krung Thai Bank PCL	2,537,200		671,798
			1,269,709
Turkey (—%)
Dogan Yayin Holding †	1		2
United Kingdom (11.2%)
Admiral Group PLC	210,929		2,422,341
ARM Holdings PLC	377,555		790,726
AstraZeneca PLC (London Exchange)	16,417		990,949
AWG PLC	68,249		1,512,030
BAE Systems PLC	921,040		6,297,875
Barclays PLC	8,701,547		98,883,932
Barratt Developments PLC	2,271,003		39,813,780
BHP Billiton PLC	473,304		9,181,699
British Airways PLC †	133,950		849,039
Bunzl PLC	17,218		196,620
Burberry Group PLC	172,783		1,373,969
easyJet PLC †	80,761		576,869
GlaxoSmithKline PLC	228,861		6,395,045
GUS PLC	79,830		1,426,102
Hays PLC	276,397		690,040
Hikma Pharmaceuticals PLC 144A	15,300		94,008
Ladbrokes PLC	6,088,856		45,884,995
IMI PLC	130,945		1,208,967
Imperial Tobacco Group PLC	89,299		2,756,197
John Wood Group PLC	152,883		661,580
Marks & Spencer PLC	234,679		2,547,532
Mitchells & Butlers PLC	182,318		1,738,063
Next PLC	41,540		1,253,701
Pennon Group PLC	69,753		1,722,073
Persimmon PLC	21,234		484,568
Punch Taverns PLC	4,809,861		77,830,165
Reckitt Benckiser PLC	2,720,442		101,624,450
Rio Tinto PLC	1,718,253		90,846,591
Royal Bank of Scotland Group PLC	1,165,966		38,337,608
Royal Bank of Scotland Group PLC 144A	29,380		966,031
Schroders PLC	327,124		6,109,999
Scottish and Southern Energy PLC	221,459		4,713,853
Stagecoach Group PLC	1,735,484		3,698,869
Tesco PLC	1,252,526		7,736,430
Travis Perkins PLC	39,825		1,114,300
Vodafone Group PLC	69,035,075		147,135,827
WPP Group PLC	135,328		1,637,965
			711,504,788
Total common stocks (cost $5,412,785,327)		$	6,298,292,773

41

UNITS (—%)* (cost $452,592)
			Units		Value
Controladora Comercial Mexicana SA de CV units (Mexico)			265,472	$	452,198
WARRANTS (—%)* † (cost $288,486)
	Expiration date	Strike price	Warrants		Value
Fuji Television Network Structured
Exercise Call Warrants 144A (issued by
Merrill Lynch International
& Co.) (Japan)	11/22/06	—	131	$	291,111
SHORT-TERM INVESTMENTS (1.2%)* (cost $75,166,205)
			Shares		Value
Putnam Prime Money Market Fund (e)			75,166,205	$	75,166,205
TOTAL INVESTMENTS
Total investments (cost $5,488,692,610)				$	6,374,202,287

* Percentages indicated are based on net assets of $6,372,415,004.

† Non-income-producing security.

(R) Real Estate Investment Trust.

(e) See Note 5 to the financial statements regarding investments in Putnam Prime Money Market Fund.

At June 30, 2006, liquid assets totaling $18,120,112 have been designated as collateral for structured warrants and open forward contracts.

144A after the name of an issuer represents securities exempt from registration under Rule 144A of the Securities Act of 1933. These securities may be resold in transactions exempt from registration, normally to qualified institutional buyers.

ADR or GDR after the name of a foreign holding stands for American Depository Receipts or Global Depository Receipts, representing ownership of foreign securities on deposit with a custodian bank.

The fund had the following industry group concentrations greater than 10% at June 30, 2006 (as a percentage of net assets):

Banking	16.8%
Oil and gas	10.1

FORWARD CURRENCY CONTRACTS TO BUY at 6/30/06 (aggregate face value $1,221,327,787)
				Unrealized
		Aggregate	Delivery	appreciation/
	Value	face value	date	(depreciation)
Australian Dollar	$271,463,062	$268,034,104	7/19/06	$ 3,428,958
British Pound	715,416,332	718,905,453	9/20/06	(3,489,121)
Euro	110,444,867	109,184,864	9/20/06	1,260,003
Japanese Yen	2,624,011	2,693,355	8/16/06	(69,344)
Norwegian Krone	91,526,314	93,708,016	9/20/06	(2,181,702)
Swedish Krona	29,231,764	28,801,995	9/20/06	429,769
Total				$ (621,437)

42

FORWARD CURRENCY CONTRACTS TO SELL at 6/30/06 (aggregate face value $1,189,146,511)
				Unrealized
		Aggregate	Delivery	appreciation/
	Value	face value	date	(depreciation)
Australian Dollar	$ 37,786,202	$ 38,567,947	7/19/06	$ 781,745
British Pound	30,457,871	30,127,389	9/20/06	(330,482)
Canadian Dollar	63,239,240	61,367,284	7/19/06	(1,871,956)
Euro	124,634,763	123,631,060	9/20/06	(1,003,703)
Japanese Yen	513,803,735	515,276,711	8/16/06	1,472,976
Norwegian Krone	32,103,651	31,662,251	9/20/06	(441,400)
Swedish Krona	82,660,570	81,692,166	9/20/06	(968,404)
Swiss Franc	306,273,738	306,821,703	9/20/06	547,965
Total				$(1,813,259)

The accompanying notes are an integral part of these financial statements.

43

Statement of assets and liabilities 6/30/06
ASSETS
Investment in securities, at value, including
Unaffiliated issuers (identified cost $5,413,526,405)	$6,299,036,082
Affiliated issuers (identified cost $75,166,205) (Note 5)	75,166,205
Cash	2,820,196
Foreign currency (cost $6,751,913) (Note 1)	6,767,609
Dividends, interest and other receivables	11,595,451
Receivable for shares of the fund sold	5,114,746
Receivable for securities sold	16,631,518
Receivable for open forward currency contracts (Note 1)	12,353,668
Receivable for closed forward currency contracts (Note 1)	15,414,820
Foreign tax reclaim receivable	2,847,747
Total assets	6,447,748,042
LIABILITIES
Payable for securities purchased	19,063,007
Payable for shares of the fund repurchased	13,626,746
Payable for compensation of Manager (Note 2)	10,241,082
Payable for investor servicing and custodian fees (Note 2)	1,669,197
Payable for Trustee compensation and expenses (Note 2)	496,152
Payable for administrative services (Note 2)	16,749
Payable for distribution fees (Note 2)	3,484,311
Payable for open forward currency contracts (Note 1)	14,788,364
Payable for closed forward currency contracts (Note 1)	11,203,042
Other accrued expenses	744,388
Total liabilities	75,333,038
Net assets	$6,372,415,004
REPRESENTED BY
Paid-in capital (Unlimited shares authorized) (Notes 1 and 4)	$5,432,252,129
Undistributed net investment income (Note 1)	85,383,146
Accumulated net realized loss on investments
and foreign currency transactions (Note 1)	(28,421,891)
Net unrealized appreciation of investments
and assets and liabilities in foreign currencies	883,201,620
Total — Representing net assets applicable to capital shares outstanding	$6,372,415,004
(Continued on next page)

44

Statement of assets and liabilities (Continued)
COMPUTATION OF NET ASSET VALUE AND OFFERING PRICE
Net asset value and redemption price per class A share
($3,601,660,909 divided by 124,975,496 shares)	$28.82
Offering price per class A share
(100/94.75 of $28.82)*	$30.42
Net asset value and offering price per class B share
($1,162,723,183 divided by 41,956,636 shares)**	$27.71
Net asset value and offering price per class C share
($264,090,096 divided by 9,348,403 shares)**	$28.25
Net asset value and redemption price per class M share
($86,932,180 divided by 3,066,238 shares)	$28.35
Offering price per class M share
(100/96.75 of $28.35)*	$29.30
Net asset value, offering price and redemption price per class R share
($3,353,975 divided by 117,232 shares)	$28.61
Net asset value, offering price and redemption price per class Y share
($1,253,654,661 divided by 43,185,185 shares)	$29.03

* On single retail sales of less than $50,000. On sales of $50,000 or more the offering price is reduced.

** Redemption price per share is equal to net asset value less any applicable contingent deferred sales charge.

The accompanying notes are an integral part of these financial statements.

45

Statement of operations Year ended 6/30/06
INVESTMENT INCOME
Dividends (net of foreign tax of $14,976,953)	$ 172,657,170
Interest (including interest income of $1,689,290
from investments in affiliated issuers) (Note 5)	2,593,922
Securities lending	24,503
Total investment income	175,275,595
EXPENSES
Compensation of Manager (Note 2)	39,476,662
Investor servicing fees (Note 2)	15,299,530
Custodian fees (Note 2)	6,653,687
Trustee compensation and expenses (Note 2)	245,510
Administrative services (Note 2)	104,354
Distribution fees — Class A (Note 2)	8,530,318
Distribution fees — Class B (Note 2)	12,990,877
Distribution fees — Class C (Note 2)	2,687,279
Distribution fees — Class M (Note 2)	682,164
Distribution fees — Class R (Note 2)	9,946
Other	1,641,840
Non-recurring costs (Notes 2 and 6)	82,555
Costs assumed by Manager (Notes 2 and 6)	(82,555)
Fees waived and reimbursed by Manager or affiliate (Notes 5 and 6)	(4,171,491)
Total expenses	84,150,676
Expense reduction (Note 2)	(4,024,193)
Net expenses	80,126,483
Net investment income	95,149,112
Net realized gain on investments (net of foreign tax of ($1,040,221) (Notes 1 and 3)	937,880,274
Net realized gain on foreign currency transactions (Note 1)	6,768,547
Net unrealized depreciation of assets and liabilities
in foreign currencies during the year	(15,465,385)
Net unrealized appreciation of investments during the year	386,970,285
Net gain on investments	1,316,153,721
Net increase in net assets resulting from operations	$1,411,302,833

The accompanying notes are an integral part of these financial statements.

46

Statement of changes in net assets
INCREASE (DECREASE) IN NET ASSETS
	Year ended	Year ended
	6/30/06	6/30/05
Operations:
Net investment income	$ 95,149,112	$ 60,388,713
Net realized gain on investments
and foreign currency transactions	944,648,821	806,769,511
Net unrealized appreciation (depreciation) of investments
and assets and liabilities in foreign currencies	371,504,900	(24,510,232)
Net increase in net assets resulting from operations	1,411,302,833	842,647,992
Distributions to shareholders: (Note 1)
From net investment income
Class A	(66,521,442)	(48,773,597)
Class B	(16,227,288)	(11,127,164)
Class C	(3,356,978)	(1,810,078)
Class M	(1,333,118)	(906,794)
Class R	(30,587)	(9,386)
Class Y	(26,170,647)	(22,229,449)
Redemption fees (Note 1)	237,700	166,514
Decrease from capital share transactions (Note 4)	(870,490,033)	(1,773,743,224)
Total increase (decrease) in net assets	427,410,440	(1,015,785,186)
NET ASSETS
Beginning of year	5,945,004,564	6,960,789,750
End of year (including undistributed net investment
income of $85,383,146 and $97,570,644, respectively)	$6,372,415,004	$5,945,004,564

The accompanying notes are an integral part of these financial statements.

47

Financial	highlights	(For a common share outstanding throughout the period)
INVESTMENT OPERATIONS:					LESS DISTRIBUTIONS:					RATIOS AND SUPPLEMENTAL DATA:
			Net						Total			Ratio of net
	Net asset		realized and	Total	From			Net asset	return	Net	Ratio of	investment
	value,	Net	unrealized	from	net			value,	at net	assets,	expenses to	income (loss)	Portfolio
	beginning	investment	gain (loss) on	investment	investment	Total	Redemption	end	asset	end of period	average net	to average	turnover
Period ended	of period	income (loss)(a)	investments	operations	income	distributions	fees	of period	value (%)(b)	(in thousands)	assets (%)(c)	net assets (%)	(%)
CLASS A
June 30, 2006	$23.39	.45(d,e,f )	5.51	5.96	(.53)	(.53)	—(h)	$28.82	25.70	$3,601,661	1.19(d,e)	1.69(d,e,f )	83.10
June 30, 2005	20.86	.25(d,g)	2.61	2.86	(.33)	(.33)	—(h)	23.39	13.71	3,137,593	1.24(d)	1.11(d,g)	74.79
June 30, 2004	17.43	.15(d)	3.63	3.78	(.35)	(.35)	—(h)	20.86	21.81	3,677,492	1.23(d)	.74(d)	69.27
June 30, 2003	19.18	.22	(1.93)	(1.71)	(.04)	(.04)	—	17.43	(8.93)	6,855,608	1.22	1.33	53.11(i)
June 30, 2002	21.24	.17	(2.23)	(2.06)	—	—	—	19.18	(9.70)	6,930,312	1.16	.85	42.17
CLASS B
June 30, 2006	$22.49	.21(d,e,f)	5.33	5.54	(.32)	(.32)	—(h)	$27.71	24.77	$1,162,723	1.94(d,e)	.81(d,e,f )	83.10
June 30, 2005	20.07	.07(d,g)	2.51	2.58	(.16)	(.16)	—(h)	22.49	12.86	1,344,142	1.99(d)	.35(d,g)	74.79
June 30, 2004	16.79	.02(d)	3.47	3.49	(.21)	(.21)	—(h)	20.07	20.84	1,577,583	1.98(d)	.12(d)	69.27
June 30, 2003	18.57	.08	(1.86)	(1.78)	—	—	—	16.79	(9.59)	1,892,054	1.97	.51	53.11(i)
June 30, 2002	20.72	.01	(2.16)	(2.15)	—	—	—	18.57	(10.38)	2,326,938	1.91	.04	42.17
CLASS C
June 30, 2006	$22.93	.23(d,e,f )	5.42	5.65	(.33)	(.33)	—(h)	$28.25	24.77	$264,090	1.94(d,e)	.87(d,e,f )	83.10
June 30, 2005	20.44	.08(d,g)	2.55	2.63	(.14)	(.14)	—(h)	22.93	12.87	259,993	1.99(d)	.34(d,g)	74.79
June 30, 2004	17.05	—(d,h)	3.55	3.55	(.16)	(.16)	—(h)	20.44	20.86	313,496	1.98(d)	.02(d)	69.27
June 30, 2003	18.86	.09	(1.90)	(1.81)	—	—	—	17.05	(9.60)	534,933	1.97	.54	53.11(i)
June 30, 2002	21.03	.01	(2.18)	(2.17)	—	—	—	18.86	(10.32)	601,907	1.91	.07	42.17
CLASS M
June 30, 2006	$23.00	.30(d,e,f )	5.44	5.74	(.39)	(.39)	—(h)	$28.35	25.12	$86,932	1.69(d,e)	1.14(d,e,f )	83.10
June 30, 2005	20.51	.13(d,g)	2.56	2.69	(.20)	(.20)	—(h)	23.00	13.13	90,499	1.74(d)	.60(d,g)	74.79
June 30, 2004	17.13	.05(d)	3.56	3.61	(.23)	(.23)	—(h)	20.51	21.13	109,648	1.73(d)	.28(d)	69.27
June 30, 2003	18.90	.11	(1.88)	(1.77)	—	—	—	17.13	(9.37)	187,266	1.72	.73	53.11(i)
June 30, 2002	21.04	.06	(2.20)	(2.14)	—	—	—	18.90	(10.17)	248,921	1.66	.30	42.17
CLASS R
June 30, 2006	$23.25	.53(d,e,f )	5.33	5.86	(.50)	(.50)	—(h)	$28.61	25.42	$3,354	1.44(d,e)	1.95(d,e,f )	83.10
June 30, 2005	20.77	.26(d,g)	2.52	2.78	(.30)	(.30)	—(h)	23.25	13.38	1,125	1.49(d)	1.17(d,g)	74.79
June 30, 2004	17.42	.18(d)	3.55	3.73	(.38)	(.38)	—(h)	20.77	21.50	559	1.48(d)	.84(d)	69.27
June 30, 2003 †	16.52	.08	.82	.90	—	—	—	17.42	5.45*	1	.65*	.47*	53.11(i)
CLASS Y
June 30, 2006	$23.55	.53(d,e,f )	5.54	6.07	(.59)	(.59)	—(h)	$29.03	26.05	$1,253,655	.94(d,e)	1.95(d,e,f )	83.10
June 30, 2005	21.01	.29(d,g)	2.64	2.93	(.39)	(.39)	—(h)	23.55	13.98	1,111,652	.99(d)	1.31(d,g)	74.79
June 30, 2004	17.57	.19(d)	3.67	3.86	(.42)	(.42)	—(h)	21.01	22.07	1,282,011	.98(d)	.98(d)	69.27
June 30, 2003	19.33	.28	(1.96)	(1.68)	(.08)	(.08)	—	17.57	(8.67)	1,968,996	.97	1.64	53.11(i)
June 30, 2002	21.35	.22	(2.24)	(2.02)	—	—	—	19.33	(9.46)	1,664,886	.91	1.13	42.17
See notes to financial highlights at the end of this section.

The accompanying notes are an integral part of these financial statements.

48                                                                                                                                                                     ;                                                                                                                                                                     49

Financial highlights (Continued)

* Not annualized.

† For the period January 21, 2003 (commencement of operations) to June 30, 2003.

(a) Per share net investment income (loss) has been determined on the basis of the weighted average number of shares outstanding during the period.

(b) Total return assumes dividend reinvestment and does not reflect the effect of sales charges.

(c) Includes amounts paid through expense offset arrangements (Note 2).

(d) Reflects an involuntary contractual expense limitation and waivers of certain fund expenses in connection with investments in Putnam Prime Market Fund during the period. As a result of such limitation and waivers, the expenses of each class, as a percentage of its net assets, reflect a reduction of the following amounts (Notes 2 and 5):

	6/30/06	6/30/05	6/30/04
Class A	<0.01%	0.06%	0.03%
Class B	<0.01	0.06	0.03
Class C	<0.01	0.06	0.03
Class M	<0.01	0.06	0.03
Class R	<0.01	0.06	0.03
Class Y	<0.01	0.06	0.03

(e) Reflects a non-recurring reimbursement from Putnam Investments relating to the calculation of certain amounts paid by the fund to Putnam in previous years for transfer agent services, which amounted to $0.02 per share and 0.07% of average net assets for the period ended June 30, 2006 (Note 6).

(f) Net investment income (loss) per share and ratio of net investment income (loss) to average net assets reflects a special dividend received by the fund which amounted to the following amounts:

		Percentage of
	Per share	net assets
Class A	$0.14	0.54%
Class B	0.13	0.51
Class C	0.14	0.52
Class M	0.14	0.53
Class R	0.18	0.66
Class Y	0.15	0.56

(g) Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices. As a result, the expenses of each class reflect a reduction of the following amounts (Note 6):

		Percentage of
	Per share	net assets
Class A	<$0.01	0.01%
Class B	<0.01	0.01
Class C	<0.01	0.01
Class M	<0.01	0.01
Class R	<0.01	0.01
Class Y	<0.01	0.01

(h) Amount represents less than $0.01 per share.

(i) Portfolio turnover excludes impact of assets received from the acquisition of Putnam Asia Pacific Fund and Putnam Emerging Markets Fund.

The accompanying notes are an integral part of these financial statements.

50

Notes to financial statements 6/30/06

Note 1: Significant accounting policies

Putnam International Equity Fund (“the fund”), a Massachusetts business trust, is registered under the Investment Company Act of 1940, as amended, as a diversified open-end management investment company. The fund seeks capital appreciation by investing primarily in equity securities of companies located outside the United States.

The fund offers class A, class B, class C, class M, class R and class Y shares. Class A and class M shares are sold with a maximum front-end sales charge of 5.25% and 3.25%, respectively, and generally do not pay a contingent deferred sales charge. Class B shares, which convert to class A shares after approximately eight years, do not pay a front-end sales charge and are subject to a contingent deferred sales charge, if those shares are redeemed within six years of purchase. Class C shares have a one-year 1.00% contingent deferred sales charge and do not convert to class A shares. Class R shares, which are offered to qualified employee-benefit plans, are sold without a front-end sales charge or a contingent deferred sales charge. The expenses for class A, class B, class C, class M and class R shares may differ based on the distribution fee of each class, which is identified in Note 2. Class Y shares, which are sold at net asset value, are generally subject to the same expenses as class A, class B, class C, class M and class R shares, but do not bear a distribution fee. Class Y shares are sold to certain eligible purchasers including certain defined contribution plans (including corporate IRAs), bank trust departments, trust companies, other Putnam funds and products, and certain college savings plans.

A 2.00% redemption fee may apply to any shares that are redeemed (either by selling or exchanging into another fund) within 5 days of purchase. A 1.00% redemption fee would apply to any shares that are redeemed (either by selling or exchanging into another fund) within 6-90 days of purchase. The redemption fee is accounted for as an addition to paid-in-capital.

Investment income, realized and unrealized gains and losses and expenses of the fund are borne pro-rata based on the relative net assets of each class to the total net assets of the fund, except that each class bears expenses unique to that class (including the distribution fees applicable to such classes). Each class votes as a class only with respect to its own distribution plan or other matters on which a class vote is required by law or determined by the Trustees. Shares of each class would receive their pro-rata share of the net assets of the fund, if the fund were liquidated. In addition, the Trustees declare separate dividends on each class of shares.

In the normal course of business, the fund enters into contracts that may include agreements to indemnify another party under given circumstances. The fund’s maximum exposure under these arrangements is unknown as this would involve future claims that may be, but have not yet been, made against the fund. However, the fund expects the risk of material loss to be remote.

The following is a summary of significant accounting policies consistently followed by the fund in the preparation of its financial statements. The preparation of financial statements is in conformity with accounting principles generally accepted in the United States of America and requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities in the financial statements and the reported amounts of increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates.

A) Security valuation Investments for which market quotations are readily available are valued at the last reported sales price on their principal exchange, or official closing price for certain markets. If no sales are reported — as in the case of some securities traded over-the-counter — a security is valued at its last reported bid price. Many securities markets and exchanges outside the U.S. close prior to the close of the New York Stock Exchange and therefore the closing prices for securities in such markets or on such

51

exchanges may not fully reflect events that occur after such close but before the close of the New York Stock Exchange. Accordingly, on certain days, the fund will fair value foreign equity securities taking into account multiple factors, including movements in the U.S. securities markets. The number of days on which fair value prices will be used will depend on market activity and it is possible that fair value prices will be used by the fund to a significant extent. Securities quoted in foreign currencies, if any, are translated into U.S. dollars at the current exchange rate. Other investments, including certain restricted securities, are valued at fair value following procedures approved by the Trustees. Such valuations and procedures are reviewed periodically by the Trustees. The fair value of securities is generally determined as the amount that the fund could reasonably expect to realize from an orderly disposition of such securities over a reasonable period of time. By its nature, a fair value price is a good faith estimate of the value of a security at a given point in time and does not reflect an actual market price.

B) Joint trading account Pursuant to an exemptive order from the Securities and Exchange Commission, the fund may transfer uninvested cash balances, including cash collateral received under security lending arrangements, into a joint trading account along with the cash of other registered investment companies and certain other accounts managed by Putnam Investment Management, LLC (“Putnam Management”), the fund’s manager, an indirect wholly-owned subsidiary of Putnam, LLC. These balances may be invested in issues of high-grade short-term investments having maturities of up to 397 days for collateral received under security lending arrangements and up to 90 days for other cash investments.

C) Repurchase agreements The fund, or any joint trading account, through its custodian, receives delivery of the underlying securities, the market value of which at the time of purchase is required to be in an amount at least equal to the resale price, including accrued interest. Collateral for certain tri-party repurchase agreements is held at the counterparty’s custodian in a segregated account for the benefit of the fund and the coun-terparty. Putnam Management is responsible for determining that the value of these underlying securities is at all times at least equal to the resale price, including accrued interest.

D) Security transactions and related investment income Security transactions are recorded on the trade date (the date the order to buy or sell is executed). Gains or losses on securities sold are determined on the identified cost basis.

Interest income is recorded on the accrual basis. Dividend income, net of applicable withholding taxes, is recognized on the ex-dividend date except that certain dividends from foreign securities, if any, are recognized as soon as the fund is informed of the ex-dividend date. Non-cash dividends, if any, are recorded at the fair market value of the securities received. Dividends representing a return of capital or capital gains, if any, are reflected as a reduction of cost and/or as a realized gain when the amounts are conclusively determined.

E) Foreign currency translation The accounting records of the fund are maintained in U.S. dollars. The market value of foreign securities, currency holdings, and other assets and liabilities are recorded in the books and records of the fund after translation to U.S. dollars based on the exchange rates on that day. The cost of each security is determined using historical exchange rates. Income and withholding taxes are translated at prevailing exchange rates when earned or incurred. The fund does not isolate that portion of realized or unrealized gains or losses resulting from changes in the foreign exchange rate on investments from fluctuations arising from changes in the market prices of the securities. Such gains and losses are included with the net realized and unrealized gain or loss on investments. Net realized gains and losses on foreign currency transactions represent net realized exchange gains or losses on closed forward currency contracts, disposition of foreign currencies, currency gains and losses realized

52

between the trade and settlement dates on securities transactions and the difference between the amount of investment income and foreign withholding taxes recorded on the fund’s books and the U.S. dollar equivalent amounts actually received or paid. Net unrealized appreciation and depreciation of assets and liabilities in foreign currencies arise from changes in the value of open forward currency contracts and assets and liabilities other than investments at the period end, resulting from changes in the exchange rate. Investments in foreign securities involve certain risks, including those related to economic instability, unfavorable political developments, and currency fluctuations, not present with domestic investments. The fund may be subject to taxes imposed by governments of countries in which it invests. Such taxes are generally based on either income or gains earned or repatriated. The fund accrues and applies such taxes to net investment income, net realized gains and net unrealized gains as income and/or capital gains are earned.

F) Forward currency contracts The fund may buy and sell forward currency contracts, which are agreements between two parties to buy and sell currencies at a set price on a future date. These contracts are used to protect against a decline in value relative to the U.S. dollar of the currencies in which its portfolio securities are denominated or quoted (or an increase in the value of a currency in which securities a fund intends to buy are denominated, when a fund holds cash reserves and short term investments), or for other investment purposes. The U.S. dollar value of forward currency contracts is determined using current forward currency exchange rates supplied by a quotation service. The market value of the contract will fluctuate with changes in currency exchange rates. The contract is marked to market daily and the change in market value is recorded as an unrealized gain or loss. When the contract is closed, the fund records a realized gain or loss equal to the difference between the value of the contract at the time it was opened and the value at the time it was closed. The fund could be exposed to risk if the value of the currency changes unfavorably, if the counterparties to the contracts are unable to meet the terms of their contracts or if the fund is unable to enter into a closing position. Risks may exceed amounts recognized on the statement of assets and liabilities. Forward currency contracts outstanding at period end, if any, are listed after the fund’s portfolio.

G) Security lending The fund may lend securities, through its agents, to qualified borrowers in order to earn additional income. The loans are collateralized by cash and/or securities in an amount at least equal to the market value of the securities loaned. The market value of securities loaned is determined daily and any additional required collateral is allocated to the fund on the next business day. The risk of borrower default will be borne by the fund’s agents; the fund will bear the risk of loss with respect to the investment of the cash collateral. Income from securities lending is included in investment income on the statement of operations. At June 30, 2006, the fund had no securities out on loan.

H) Federal taxes It is the policy of the fund to distribute all of its taxable income within the prescribed time and otherwise comply with the provisions of the Internal Revenue Code of 1986 (the “Code”) applicable to regulated investment companies. It is also the intention of the fund to distribute an amount sufficient to avoid imposition of any excise tax under Section 4982 of the Code, as amended. Therefore, no provision has been made for federal taxes on income, capital gains or unrealized appreciation on securities held nor for excise tax on income and capital gains.

At June 30, 2006, the fund had a capital loss carryover of $43,695,458 available to the extent allowed by the Code to offset future net capital gain, if any. The amount of the carryover and the expiration dates are:

Loss Carryover	Expiration
$23,474,190	June 30, 2008
20,221,268	June 30, 2011

53

I) Distributions to shareholders Distributions to shareholders from net investment income are recorded by the fund on the ex-dividend date. Distributions from capital gains, if any, are recorded on the ex-dividend date and paid at least annually. The amount and character of income and gains to be distributed are determined in accordance with income tax regulations, which may differ from generally accepted accounting principles. These differences include temporary and permanent differences of losses on wash sale transactions and foreign currency gains and losses. Reclassifications are made to the fund’s capital accounts to reflect income and gains available for distribution (or available capital loss carryovers) under income tax regulations. For the year ended June 30, 2006, the fund reclassified $6,303,450 to increase undistributed net investment income with an increase to accumulated net realized losses of $6,303,450.

The tax basis components of distributable earnings and the federal tax cost as of June 30, 2006 were as follows:

Unrealized appreciation	$1,042,736,888
Unrealized depreciation	(189,116,182)
	—————————
Net unrealized appreciation	853,620,706
Undistributed ordinary income	82,948,449
Undistributed long term gain	47,162,541
Capital loss carryforward	(43,695,458)
Cost for federal income
tax purposes	$5,520,581,581

Note 2: Management fee, administrative
services and other transactions

Putnam Management is paid for management and investment advisory services quarterly based on the average net assets of the fund. Such fee is based on the following annual rates: : 0.80% of the first $500 million of average net assets, 0.70% of the next $500 million, 0.65% of the next $500 million, 0.60% of the next $5 billion, 0.575% of the next $5 billion, 0.555% of the next $5 billion, 0.54% of the next $5 billion, and 0.53% thereafter.

Putnam Management has agreed to waive fees and reimburse expenses of the fund through June 30, 2007 to the extent necessary to ensure that the fund’s expenses do not exceed the simple average of the expenses of all front-end load funds viewed by Lipper Inc. as having the same investment classification or objective as the fund. The expense reimbursement is based on a comparison of the fund’s expenses with the average annualized operating expenses of the funds in its Lipper peer group for each calendar quarter during the fund’s last fiscal year, excluding 12b-1 fees and without giving effect to any expense offset and brokerage service arrangements that may reduce fund expenses. For the year ended June 30, 2006, Putnam Management did not waive any of its management fee from the fund.

For year ended June 30, 2006, Putnam Management has assumed $82,555 of legal, shareholder servicing and communication, audit and Trustee fees incurred by the fund in connection with certain legal and regulatory matters (including those described in Note 6).

Putnam Investments Limited (“PIL”), an affiliate of Putnam Management, is authorized by the Trustees to manage a separate portion of the assets of the fund as determined by Putnam Management from time to time. Putnam Management pays a quarterly sub-management fee to PIL for its services at an annual rate of 0.35% of the average net assets of the portion of the fund managed by PIL.

Effective July 2006, The Putnam Advisory Company, LLC ("PAC"), an affiliate of Putnam Management, is authorized by the Trustees to act as a sub-adviser to provide investment recommendations with respect to a portion of the assets of the fund, as designated from time to time by Putnam Management or PIL. Putnam Management or PIL, as applicable, pays a quarterly sub-advisory fee to PAC for its services at the annual rate of 0.10% of the average net assets of the portion of the fund’s assets for which PAC is engaged as sub-adviser.

The fund reimburses Putnam Management an allocated amount for the compensation and related expenses of certain officers of the fund and their

54

staff who provide administrative services to the fund. The aggregate amount of all such reimbursements is determined annually by the Trustees.

Custodial functions for the fund’s assets are provided by Putnam Fiduciary Trust Company (“PFTC”), a subsidiary of Putnam, LLC. PFTC receives fees for custody services based on the fund’s asset level, the number of its security holdings and transaction volumes. Putnam Investor Services, a division of PFTC, provides investor servicing agent functions to the fund. Putnam Investor Services receives fees for investor servicing based on the number of shareholder accounts in the fund and the level of defined contribution plan assets in the fund. During the year ended June 30, 2006, the fund incurred $21,953,217 for these services.

The fund has entered into an arrangement with PFTC whereby credits realized as a result of uninvested cash balances are used to reduce a portion of the fund’s expenses. For the year ended June 30, 2006, the fund’s expenses were reduced by $4,024,193 under these arrangements.

Each independent Trustee of the fund receives an annual Trustee fee, of which $1,425 as a quarterly retainer, has been allocated to the fund, and an additional fee for each Trustees meeting attended. Trustees receive additional fees for attendance at certain committee meetings, industry seminars and for certain compliance-related matters. Trustees also are reimbursed for expenses they incur relating to their services as Trustees. George Putnam, III, who is not an independent Trustee, also receives the foregoing fees for his services as Trustee. The fund has adopted a Trustee Fee Deferral Plan (the “Deferral Plan”) which allows the Trustees to defer the receipt of all or a portion of Trustees fees payable on or after July 1, 1995. The deferred fees remain invested in certain Putnam funds until distribution in accordance with the Deferral Plan. The fund has adopted an unfunded noncontribu-tory defined benefit pension plan (the “Pension Plan”) covering all Trustees of the fund who have

served as a Trustee for at least five years and were first elected prior to 2004. Benefits under the Pension Plan are equal to 50% of the Trustee’s average annual attendance and retainer fees for the three years ended December 31, 2005. Pension expense for the fund is included in Trustee compensation and expenses in the statement of operations. Accrued pension liability is included in Payable for Trustee compensation and expenses in the statement of assets and liabilities. The Trustees have terminated the Pension Plan with respect to any Trustee first elected after 2003.

The fund has adopted distribution plans (the “Plans”) with respect to its class A, class B, class C, class M and class R shares pursuant to Rule 12b-1 under the Investment Company Act of 1940. The purpose of the Plans is to compensate Putnam Retail Management, a wholly-owned subsidiary of Putnam, LLC and Putnam Retail Management GP, Inc., for services provided and expenses incurred in distributing shares of the fund. The Plans provide for payments by the fund to Putnam Retail Management at an annual rate of up to 0.35%, 1.00%, 1.00% ,1.00% and 1.00% of the average net assets attributable to class A, class B, class C, class M and class R shares, respectively. The Trustees have approved payment by the fund at an annual rate of 0.25%, 1.00%, 1.00%, 0.75% and 0.50% of the average net assets attributable to class A, class B, class C, class M and class R shares, respectively.

For the year ended June 30, 2006, Putnam Retail Management, acting as underwriter, received net commissions of $160,361 and $2,162 from the sale of class A and class M shares, respectively, and received $1,218,701 and $6,733 in contingent deferred sales charges from redemptions of class B and class C shares, respectively. A deferred sales charge of up to 1.00% and 0.65% is assessed on certain redemptions of class A and class M shares, respectively. For the year ended June 30, 2006, Putnam Retail Management, acting as underwriter, received $2,312 and no monies on class A and class M redemptions, respectively.

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Note 3: Purchases and sales of securities

During the year ended June 30, 2006, cost of purchases and proceeds from sales of investment securities other than short-term investments aggregated $5,178,774,462 and $6,097,588,234, respectively. There were no purchases or sales of U.S. government securities.

Note 4: Capital shares

At June 30, 2006, there was an unlimited number of shares of beneficial interest authorized. Transactions in capital shares were as follows:

CLASS A	Shares		Amount
Year ended 6/30/06:
Shares sold	31,824,846	$	859,124,883
Shares issued
in connection
with reinvestment
of distributions	2,363,576		61,783,710
	34,188,422		920,908,593
Shares
repurchased	(43,371,248)		(1,154,597,530)
Net decrease	(9,182,826)	$	(233,688,937)
Year ended 6/30/05:
Shares sold	29,246,262	$	659,058,376
Shares issued
in connection
with reinvestment
of distributions	1,987,429		45,810,180
	31,233,691		704,868,556
Shares
repurchased	(73,384,430)		(1,631,089,568)
Net decrease	(42,150,739)	$	(926,221,012)

CLASS B	Shares		Amount
Year ended 6/30/06:
Shares sold	2,232,332	$	57,923,836
Shares issued
in connection
with reinvestment
of distributions	564,972		14,254,269
	2,797,304		72,178,105
Shares
repurchased	(20,607,087)		(528,802,577)
Net decrease	(17,809,783)	$	(456,624,472)
Year ended 6/30/05:
Shares sold	3,015,103	$	65,482,288
Shares issued
in connection
with reinvestment
of distributions	439,024		9,768,291
	3,454,127		75,250,579
Shares
repurchased	(22,291,909)		(482,073,054)
Net decrease	(18,837,782)		$(406,822,475)
CLASS C	Shares		Amount
Year ended 6/30/06:
Shares sold	718,393	$	19,065,351
Shares issued
in connection
with reinvestment
of distributions	101,427		2,608,692
	819,820		21,674,043
Shares
repurchased	(2,810,983)		(73,542,043)
Net decrease	(1,991,163)	$	(51,868,000)
Year ended 6/30/05:
Shares sold	707,079	$	15,642,603
Shares issued
in connection
with reinvestment
of distributions	61,825		1,402,820
	768,904		17,045,423
Shares
repurchased	(4,766,485)		(103,823,967)
Net decrease	(3,997,581)	$	(86,778,544)

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CLASS M	Shares		Amount
Year ended 6/30/06:
Shares sold	563,159	$	15,066,847
Shares issued
in connection
with reinvestment
of distributions	49,435		1,274,437
	612,594		16,341,284
Shares
repurchased	(1,480,314)		(38,785,358)
Net decrease	(867,720)	$	(22,444,074)
Year ended 6/30/05:
Shares sold	655,911	$	14,535,490
Shares issued
in connection
with reinvestment
of distributions	38,150		867,147
	694,061		15,402,637
Shares
repurchased	(2,105,951)		(45,878,747)
Net decrease	(1,411,890)	$	(30,476,110)
CLASS R	Shares		Amount
Year ended 6/30/06:
Shares sold	100,684	$	2,762,299
Shares issued
in connection
with reinvestment
of distributions	1,137		29,541
	101,821		2,791,840
Shares
repurchased	(32,968)		(908,415)
Net increase	68,853	$	1,883,425
Year ended 6/30/05:
Shares sold	37,405	$	860,756
Shares issued
in connection
with reinvestment
of distributions	388		8,910
	37,793		869,666
Shares
repurchased	(16,326)		(380,945)
Net increase	21,467	$	488,721

CLASS Y	Shares		Amount
Year ended 6/30/06:
Shares sold	13,024,491	$	353,986,997
Shares issued
in connection
with reinvestment
of distributions	995,460		26,170,647
	14,019,951		380,157,644
Shares
repurchased	(18,034,893)		(487,905,619)
Net decrease	(4,014,942)	$	(107,747,975)
Year ended 6/30/05:
Shares sold	16,052,920	$	363,546,592
Shares issued
in connection
with reinvestment
of distributions	958,993		22,229,449
	17,011,913		385,776,041
Shares
repurchased	(30,831,880)		(709,709,845)
Net decrease	(13,819,967)	$	(323,933,804)

Note 5: Investment in Putnam Prime
Money Market Fund

Pursuant to an exemptive order from the Securities and Exchange Commission, the fund invests in Putnam Prime Money Market Fund, an open-end management investment company managed by Putnam Management. Management fees paid by the fund are reduced by an amount equal to the management and administrative services fees paid by Putnam Prime Money Market Fund with respect to assets invested by the fund in Putnam Prime Money Market Fund. For the year ended June 30, 2006, management fees paid were reduced by $51,222 relating to the fund’s investment in Putnam Prime Money Market Fund. Income distributions earned by the fund are recorded as income in the statement of operations and totaled $1,689,290 for the year ended June 30, 2006. During the year ended June 30, 2006, cost of purchases and cost of sales of investments in Putnam Prime Money Market Fund aggregated $1,944,547,945 and $1,947,288,856, respectively.

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Note 6: Regulatory matters and litigation

Putnam Management has entered into agreements with the Securities and Exchange Commission and the Massachusetts Securities Division settling charges connected with excessive short-term trading by Putnam employees and, in the case of the charges brought by the Massachusetts Securities Division, by participants in some Putnam-administered 401(k) plans. Pursuant to these settlement agreements, Putnam Management will pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to certain open-end funds and their shareholders. The amount will be allocated to shareholders and funds pursuant to a plan developed by an independent consultant, and will be paid following approval of the plan by the SEC and the Massachusetts Securities Division.

The Securities and Exchange Commission’s and Massachusetts Securities Division’s allegations and related matters also serve as the general basis for numerous lawsuits, including purported class action lawsuits filed against Putnam Management and certain related parties, including certain Putnam funds. Putnam Management will bear any costs incurred by Putnam funds in connection with these lawsuits. Putnam Management believes that the likelihood that the pending private lawsuits and purported class action lawsuits will have a material adverse financial impact on the fund is remote, and the pending actions are not likely to materially affect its ability to provide investment management services to its clients, including the Putnam funds.

Pursuant to a settlement with the Securities and Exchange Commission relating to Putnam Management’s brokerage allocation practices, on October 13, 2005 the fund received $1,120,592 in proceeds paid by Putnam Management. The fund had accrued a receivable for this amount in the prior fiscal year.

In March 2006, the fund received $4,120,269 from Putnam to address issues relating to the calculation of certain amounts paid by the Putnam mutual funds to Putnam for transfer agent services. This amount is included in Fees waived and reimbursed by Manager or affiliate on the Statement of operations. Review of this matter is ongoing and the amount received by the fund may be adjusted in the future. Such adjustment is not expected to be material.

Putnam Management and Putnam Retail Management are named as defendants in a civil suit in which the plaintiffs allege that the management and distribution fees paid by certain Putnam funds were excessive and seek recovery under the Investment Company Act of 1940. Putnam Management and Putnam Retail Management have contested the plaintiffs’ claims and the matter is currently pending in the U.S. District Court for the District of Massachusetts. Based on currently available information, Putnam Management believes that this action is without merit and that it is unlikely to have a material effect on Putnam Management’s and Putnam Retail Management’s ability to provide services to their clients, including the fund.

Note 7: New Accounting Pronouncement

In June 2006, FASB issued Interpretation No. 48, Accounting for Uncertainty in Income Taxes (the “Interpretation”). The Interpretation prescribes a minimum threshold for financial statement recognition of the benefit of a tax position taken or expected to be taken by a filer in the filer’s tax return. The Interpretation will become effective for fiscal years beginning after December 15, 2006 but will also apply to tax positions reflected in the fund’s financial statements as of that date. No determination has been made whether the adoption of the Interpretation will require the fund to make any adjustments to its net assets or have any other effect on the fund’s financial statements.

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Federal tax information
(Unaudited)

Pursuant to Section 852 of the Internal Revenue Code, as amended, the fund hereby designates $47,162,541 as long term capital gain, for its taxable year ended June 30, 2006.

For the period, interest and dividends from foreign countries were $187,625,641 for all classes of shares. Taxes paid to foreign countries were $16,017,174 for all classes of shares.

For its tax year ended June 30, 2006, the fund herby designates 100% or the maximum amount allowable, of its taxable ordinary income distributions as qualified dividends taxed at the individual net capital gain rates.

The Form 1099 you receive in January 2007 will show the tax status of all distributions paid to your account in calendar 2006.

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Brokerage commissions
(Unaudited)

Brokerage commissions are paid to firms that execute trades on behalf of your fund. When choosing these firms, Putnam is required by law to seek the best execution of the trades, taking all relevant factors into consideration, including expected quality of execution and commission rate. Listed below are the largest relationships based upon brokerage commissions for your fund and the other funds in Putnam’s International group for the year ended June 30, 2006. The other Putnam mutual funds in this group are Putnam Europe Equity Fund, Putnam Global Equity Fund, Putnam International Capital Opportunities Fund, Putnam International Growth and Income Fund, Putnam International New Opportunities Fund, Putnam VT Global Equity Fund, Putnam VT International Equity Fund, Putnam VT International Growth and Income Fund, and Putnam VT International New Opportunities Fund.

The top five firms that received brokerage commissions for trades executed for the International group are (in descending order) Goldman Sachs, Credit Suisse First Boston, UBS Warburg, Merrill Lynch, and Citigroup Global Markets. Commissions paid to these firms together represented approximately 52% of the total brokerage commissions paid for the year ended June 30, 2006.

Commissions paid to the next 10 firms together represented approximately 36% of the total brokerage commissions paid during the period. These firms are (in alphabetical order) ABN AMRO U.S., Bear Stearns & Company, Cazenove, Deutsche Bank Securities, Hong Kong Shanghai Banking Corp., JP Morgan Clearing, Lehman Brothers, Morgan Stanley Dean Witter, Nomura Securities, and Santander Investment Securities.

Additional information about brokerage commissions is available on the Securities and Exchange Commission (SEC) Web site at www.sec.gov. Putnam funds disclose commissions by firm to the SEC in semiannual filings on Form N-SAR.

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About the Trustees

Jameson A. Baxter (Born 1943), Trustee since 1994, Vice Chairman since 2005

Ms. Baxter is the President of Baxter Associates, Inc., a private investment firm that she founded in 1986.

Ms. Baxter serves as a Director of ASHTA Chemicals, Inc., Banta Corporation (a printing and digital imaging firm), Ryerson Tull, Inc. (a steel service corporation), the Mutual Fund Directors Forum, Advocate Health Care and BoardSource, formerly the National Center for Nonprofit Boards. She is Chairman Emeritus of the Board of Trustees, Mount Holyoke College, having served as Chairman for five years and as a board member for thirteen years. Until 2002, Ms. Baxter was a Director of Intermatic Corporation (a manufacturer of energy control products).

Ms. Baxter has held various positions in investment banking and corporate finance, including Vice President and Principal of the Regency Group, and Vice President of and Consultant to First Boston Corporation. She is a graduate of Mount Holyoke College.

Charles B. Curtis (Born 1940), Trustee since 2001

Mr. Curtis is President and Chief Operating Officer of the Nuclear Threat Initiative (a private foundation dealing with national security issues) and serves as Senior Advisor to the United Nations Foundation.

Mr. Curtis is a member of the Council on Foreign Relations and the Trustee Advisory Council of the Applied Physics Laboratory, Johns Hopkins University. Until 2003, Mr. Curtis was a member of the Electric Power Research Institute Advisory Council and the University of Chicago Board of Governors for Argonne National Laboratory. Prior to 2002, Mr. Curtis was a Member of the Board of Directors of the Gas Technology Institute and the Board of Directors of the Environment and Natural Resources Program Steering Committee, John F. Kennedy School of Government, Harvard University. Until 2001, Mr. Curtis was a member of the Department of Defense Policy Board and Director of EG&G Technical Services, Inc. (a fossil energy research and development support company).

From August 1997 to December 1999, Mr. Curtis was a Partner at Hogan & Hartson L.L.P., a Washington, D.C. law firm. Prior to May 1997, Mr. Curtis was Deputy Secretary of Energy and Under Secretary of the U.S. Department of Energy. He served as Chairman of the Federal Energy Regulatory Commission from 1977 to 1981 and has held positions on the staff of the U.S. House of Representatives, the U.S. Treasury Department, and the SEC.

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Myra R. Drucker (Born 1948), Trustee since 2004

Ms. Drucker is a Vice Chair of the Board of Trustees of Sarah Lawrence College, Vice Chair of the Board of Trustees of the Commonfund (a not-for-profit firm specializing in asset management for educational endowments and foundations) and a member of the Investment Committee of the Kresge Foundation (a charitable trust).

Ms. Drucker is an ex-officio member of the New York Stock Exchange (NYSE) Pension Managers Advisory Committee, having served as Chair for seven years and a member of the Executive Committee of the Committee on Investment of Employee Benefit Assets. She is Chair of the Advisory Board of Hamilton Lane Advisors (an investment management firm) and a member of the Advisory Board of RCM (an investment management firm). Until August 31, 2004, Ms. Drucker was Managing Director and a member of the Board of Directors of General Motors Asset Management and Chief Investment Officer of General Motors Trust Bank. Ms. Drucker also served as a member of the NYSE Corporate Accountability and Listing Standards Committee and the NYSE/NASD IPO Advisory Committee.

Prior to joining General Motors Asset Management in 2001, Ms. Drucker held various executive positions in the investment management industry. Ms. Drucker served as Chief Investment Officer of Xerox Corporation (a technology and service company in the document industry), where she was responsible for the investment of the company’s pension assets. Ms. Drucker was also Staff Vice President and Director of Trust Investments for International Paper (a paper, paper distribution, packaging and forest products company) and previously served as Manager of Trust Investments for Xerox Corporation. Ms. Drucker received a B.A. degree in Literature and Psychology from Sarah Lawrence College and pursued graduate studies in economics, statistics and portfolio theory at Temple University.

John A. Hill (Born 1942), Trustee since 1985 and Chairman since 2000

Mr. Hill is Vice Chairman of First Reserve Corporation, a private equity buyout firm that specializes in energy investments in the diversified worldwide energy industry.

Mr. Hill is a Director of Devon Energy Corporation, TransMontaigne Oil Company and various private companies controlled by First Reserve Corporation, as well as Chairman of TH Lee, Putnam Investment Trust (a closed-end investment company advised by an affiliate of Putnam Management). He is also a Trustee of Sarah Lawrence College. Until 2005, he was a Director of Continuum Health Partners of New York.

Prior to acquiring First Reserve Corporation in 1983, Mr. Hill held executive positions in investment banking and investment management with several firms and with the federal government, including Deputy Associate Director of the Office of Management and Budget and Deputy

62

Director of the Federal Energy Administration. He is active in various business associations, including the Economic Club of New York, and lectures on energy issues in the United States and Europe. Mr. Hill holds a B.A. degree in Economics from Southern Methodist University and pursued graduate studies there as a Woodrow Wilson Fellow.

Paul L. Joskow (Born 1947), Trustee since 1997

Dr. Joskow is the Elizabeth and James Killian Professor of Economics and Management, and Director of the Center for Energy and Environmental Policy Research at the Massachusetts Institute of Technology.

Dr. Joskow serves as a Director of National Grid plc (a UK-based holding company with interests in electric and gas transmission and distribution and telecommunications infrastructure) and TransCanada Corporation (an energy company focused on natural gas transmission and power services). He also serves on the Board of Overseers of the Boston Symphony Orchestra. Prior to February 2005, he served on the board of the Whitehead Institute for Biomedical Research (a non-profit research institution) and has been President of the Yale University Council since 1993. Prior to February 2002, he was a Director of State Farm Indemnity Company (an automobile insurance company), and, prior to March 2000, he was a Director of New England Electric System (a public utility holding company).

Dr. Joskow has published five books and numerous articles on topics in industrial organization, government regulation of industry, and competition policy. He is active in industry restructuring, environmental, energy, competition and privatization policies — serving as an advisor to governments and corporations worldwide. Dr. Joskow holds a Ph.D. and M. Phil from Yale University and a B.A. from Cornell University.

Elizabeth T. Kennan (Born 1938), Trustee since 1992

Dr. Kennan is a Partner of Cambus-Kenneth Farm (thoroughbred horse and cattle breeding). She is President Emeritus of Mount Holyoke College.

Dr. Kennan served as Chairman and is now Lead Director of Northeast Utilities. Until 2005, she was a Director of Talbots, Inc. She has served as Director on a number of other boards, including Bell Atlantic, Chastain Real Estate, Shawmut Bank, Berkshire Life Insurance and Kentucky Home Life Insurance. She is a Trustee of the National Trust for Historic Preservation, of Centre College and of Midway College in Midway, Kentucky. Until 2006, she was a member of The Trustees of Reservations. Dr. Kennan has served on the oversight committee of the Folger Shakespeare Library, as President of Five Colleges Incorporated, as a Trustee of Notre Dame University and is active in various educational and civic associations.

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As a member of the faculty of Catholic University for twelve years, until 1978, Dr. Kennan directed the post-doctoral program in Patristic and Medieval Studies, taught history and published numerous articles. Dr. Kennan holds a Ph.D. from the University of Washington in Seattle, an M.S. from St. Hilda’s College at Oxford University and an A.B. from Mount Holyoke College. She holds several honorary doctorates.

Robert E. Patterson (Born 1945), Trustee since 1984

Mr. Patterson is Senior Partner of Cabot Properties, L.P. and Chairman of Cabot Properties, Inc. (a private equity firm investing in commercial real estate).

Mr. Patterson serves as Chairman Emeritus and Trustee of the Joslin Diabetes Center and as a Director of Brandywine Trust Group, LLC. Prior to June 2003, he was a Trustee of Sea Education Association. Prior to December 2001, he was President and Trustee of Cabot Industrial Trust (a publicly traded real estate investment trust). Prior to February 1998, he was Executive Vice President and Director of Acquisitions of Cabot Partners Limited Partnership (a registered investment adviser involved in institutional real estate investments). Prior to 1990, he served as Executive Vice President of Cabot, Cabot & Forbes Realty Advisors, Inc. (the predecessor company of Cabot Partners).

Mr. Patterson practiced law and held various positions in state government and was the founding Executive Director of the Massachusetts Industrial Finance Agency. Mr. Patterson is a graduate of Harvard College and Harvard Law School.

W. Thomas Stephens (Born 1942), Trustee since 1997

Mr. Stephens is Chairman and Chief Executive Officer of Boise Cascade, L.L.C. (a paper, forest products and timberland assets company).

Until 2005, Mr. Stephens was a director of TransCanadaPipelines, Ltd. Until 2004, Mr. Stephens was a Director of Xcel Energy Incorporated (a public utility company), Qwest Communications, and Norske Canada, Inc. (a paper manufacturer). Until 2003, Mr. Stephens was a Director of Mail-Well, Inc. (a diversified printing company). He served as Chairman of Mail-Well until 2001 and as CEO of MacMillan-Bloedel, Ltd. (a forest products company) until 1999.

Prior to 1996, Mr. Stephens was Chairman and Chief Executive Officer of Johns Manville Corporation. He holds B.S. and M.S. degrees from the University of Arkansas.

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Richard B. Worley (Born 1945), Trustee since 2004

Mr. Worley is Managing Partner of Permit Capital LLC, an investment management firm.

Mr. Worley serves on the Executive Committee of the University of Pennsylvania Medical Center, is a Trustee of The Robert Wood Johnson Foundation (a philanthropic organization devoted to health care issues) and is a Director of The Colonial Williamsburg Foundation (a historical preservation organization). Mr. Worley also serves on the investment committees of Mount Holyoke College and World Wildlife Fund (a wildlife conservation organization).

Prior to joining Permit Capital LLC in 2002, Mr. Worley served as Chief Strategic Officer of Morgan Stanley Investment Management. He previously served as President, Chief Executive Officer and Chief Investment Officer of Morgan Stanley Dean Witter Investment Management and as a Managing Director of Morgan Stanley, a financial services firm. Mr. Worley also was the Chairman of Miller Anderson & Sherrerd, an investment management firm.

Mr. Worley holds a B.S. degree from University of Tennessee and pursued graduate studies in economics at the University of Texas.

Charles E. Haldeman, Jr.* (Born 1948), Trustee since 2004

Mr. Haldeman is President and Chief Executive Officer of Putnam, LLC (“Putnam Investments”). He is a member of Putnam Investments’ Executive Board of Directors and Advisory Council. Prior to November 2003, Mr. Haldeman served as Co-Head of Putnam Investments’ Investment Division.

Prior to joining Putnam Investments in 2002, Mr. Haldeman held executive positions in the investment management industry. He previously served as Chief Executive Officer of Delaware Investments and President & Chief Operating Officer of United Asset Management. Mr. Haldeman was also a partner and director of Cooke & Bieler, Inc. (an investment management firm).

Mr. Haldeman currently serves on the Board of Governors of the Investment Company Institute and as a Trustee of Dartmouth College, and he is a member of the Partners HealthCare Systems Investment Committee. He is a graduate of Dartmouth College, Harvard Law School and Harvard Business School. Mr. Haldeman is also a Chartered Financial Analyst (CFA) charterholder.

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George Putnam, III* (Born 1951), Trustee since 1984 and President since 2000

Mr. Putnam is President of New Generation Research, Inc. (a publisher of financial advisory and other research services), and of New Generation Advisers, Inc. (a registered investment advisor to private funds). Mr. Putnam founded the New Generation companies in 1986. Mr. Putnam is a Director of The Boston Family Office, LLC (a registered investment adviser). He is a Trustee of St. Mark’s School and Shore Country Day School, and until 2002 was a Trustee of the Sea Education Association.

Mr. Putnam previously worked as an attorney with the law firm of Dechert LLP (formerly known as Dechert Price & Rhoads) in Philadelphia. He is a graduate of Harvard College, Harvard Business School and Harvard Law School.

The address of each Trustee is One Post Office Square, Boston, MA 02109.

As of June 30, 2006, there were 108 Putnam Funds. All Trustees serve as Trustees of all Putnam funds.

Each Trustee serves for an indefinite term, until his or her resignation, retirement at age 72, death, or removal.

* Trustees who are or may be deemed to be “interested persons” (as defined in the Investment Company Act of 1940) of the fund, Putnam Management, Putnam Retail Management, or Marsh & McLennan Companies, Inc., the parent company of Putnam, LLC and its affiliated companies. Messrs. Haldeman and Putnam, III are deemed “interested persons” by virtue of their positions as officers of the fund, Putnam Management or Putnam Retail Management and as shareholders of Marsh & McLennan Companies, Inc. Mr. Putnam, III is the President of your fund and each of the other Putnam funds. Mr. Haldeman is President and Chief Executive Officer of Putnam Investments.

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Officers

In addition to George Putnam, III, the other officers of the fund are shown below:

Charles E. Porter (Born 1938)	Richard S. Robie, III (Born 1960)
Executive Vice President, Associate Treasurer,	Vice President
Compliance Liaison and Principal	Since 2004
Executive Officer
Since 1989	Senior Managing Director, Putnam
	Investments, Putnam Management
Jonathan S. Horwitz (Born 1955)	and Putnam Retail Management. Prior
Senior Vice President and Treasurer	to 2003, Senior Vice President, United
Since 2004	Asset Management Corporation
Prior to 2004, Managing Director,	Francis J. McNamara, III (Born 1955)
Putnam Investments	Vice President and Chief Legal Officer
	Since 2004
Steven D. Krichmar (Born 1958)
Vice President and Principal Financial Officer	Senior Managing Director, Putnam
Since 2002	Investments, Putnam Management
	and Putnam Retail Management. Prior
Senior Managing Director, Putnam	to 2004, General Counsel, State Street
Investments. Prior to July 2001, Partner,	Research & Management Company
PricewaterhouseCoopers LLP
	Charles A. Ruys de Perez (Born 1957)
Michael T. Healy (Born 1958)	Vice President and Chief Compliance Officer
Assistant Treasurer and Principal	Since 2004
Accounting Officer
Since 2000	Managing Director, Putnam Investments
Managing Director, Putnam Investments	Mark C. Trenchard (Born 1962)
	Vice President and BSA Compliance Officer
Beth S. Mazor (Born 1958)	Since 2002
Vice President
Since 2002	Managing Director, Putnam Investments
Managing Director, Putnam Investments	Judith Cohen (Born 1945)
	Vice President, Clerk and Assistant Treasurer
James P. Pappas (Born 1953)	Since 1993
Vice President
Since 2004	Wanda M. McManus (Born 1947)
	Vice President, Senior Associate Treasurer
Managing Director, Putnam Investments	and Assistant Clerk
and Putnam Management. During 2002,	Since 2005
Chief Operating Officer, Atalanta/Sosnoff
Management Corporation; prior to 2001,	Nancy E. Florek (Born 1957)
President and Chief Executive Officer,	Vice President, Assistant Clerk,
UAM Investment Services, Inc.	Assistant Treasurer and Proxy Manager
	Since 2005

The address of each Officer is One Post Office Square, Boston, MA 02109.

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Fund information

Founded over 65 years ago, Putnam Investments was built around the concept that a balance between risk and reward is the hallmark of a well-rounded financial program. We manage over 100 mutual funds in growth, value, blend, fixed income, and international.

Investment Manager	Trustees	Beth S. Mazor
Putnam Investment	John A. Hill, Chairman	Vice President
Management, LLC	Jameson Adkins Baxter,
One Post Office Square	Vice Chairman	James P. Pappas
Boston, MA 02109	Charles B. Curtis	Vice President
	Myra R. Drucker
Investment Sub-Manager	Charles E. Haldeman, Jr.	Richard S. Robie, III
Putnam Investments Limited	Paul L. Joskow	Vice President
57-59 St. James Street	Elizabeth T. Kennan
London, England SW1A 1LD	Robert E. Patterson	Francis J. McNamara, III
	George Putnam, III	Vice President and
Investment Sub-Adviser	W. Thomas Stephens	Chief Legal Officer
The Putnam Advisory	Richard B. Worley
Company, LLC		Charles A. Ruys de Perez
One Post Office Square	Officers	Vice President and
Boston, MA 02109	George Putnam, III	Chief Compliance Officer
	President
Marketing Services		Mark C. Trenchard
Putnam Retail Management	Charles E. Porter	Vice President and
One Post Office Square	Executive Vice President,	BSA Compliance Officer
Boston, MA 02109	Associate Treasurer, Compliance
	Liaison and Principal	Judith Cohen
Custodian	Executive Officer	Vice President, Clerk and
Putnam Fiduciary		Assistant Treasurer
Trust Company	Jonathan S. Horwitz
	Senior Vice President	Wanda M. McManus
Legal Counsel	and Treasurer	Vice President, Senior Associate
Ropes & Gray LLP		Treasurer and Assistant Clerk
	Steven D. Krichmar
Independent Registered	Vice President and	Nancy E. Florek
Public Accounting Firm	Principal Financial Officer	Vice President, Assistant Clerk,
PricewaterhouseCoopers LLP		Assistant Treasurer and
	Michael T. Healy	Proxy Manager
	Assistant Treasurer and
	Principal Accounting Officer

This report is for the information of shareholders of Putnam International Equity Fund. It may also be used as sales literature when preceded or accompanied by the current prospectus, the most recent copy of Putnam’s Quarterly Performance Summary, and Putnam’s Quarterly Ranking Summary. For more recent performance, please visit www.putnam.com. Investors should carefully consider the investment objective, risks, charges, and expenses of a fund, which are described in its prospectus. For this and other information or to request a prospectus, call 1-800-225-1581 toll free. Please read the prospectus carefully before investing. The fund’s Statement of Additional Information contains additional information about the fund’s Trustees and is available without charge upon request by calling 1-800-225-1581.s

68

Item 2. Code of Ethics:

(a) The fund’s principal executive, financial and accounting officers are employees of Putnam Investment Management, LLC, the Fund's investment manager. As such they are subject to a comprehensive Code of Ethics adopted and administered by Putnam Investments which is designed to protect the interests of the firm and its clients. The Fund has adopted a Code of Ethics which incorporates the Code of Ethics of Putnam Investments with respect to all of its officers and Trustees who are employees of Putnam Investment Management, LLC. For this reason, the Fund has not adopted a separate code of ethics governing its principal executive, financial and accounting officers.

(c) In July 2005, Putnam Investment Management, LLC, the Fund's investment manager, Putnam Retail Management Limited Partnership, the Fund's principal underwriter, and Putnam Investments Limited, the sub-manager for a portion of the assets of certain funds as determined by Putnam Management from time to time, adopted several amendments to their Code of Ethics. Insofar as such Code of Ethics applies to the Fund's principal executive officer, principal financial officer and principal accounting officer, the amendments provided for an exception to the standard 90-day holding period (one year, in the case of employees deemed to be “access persons” under the Code) for shares of Putnam mutual funds in the case of redemptions from an employee’s account in a college savings plan qualified under Section 529 of the Internal Revenue Code. Under this exception, an employee may, without penalty under the Code, make “qualified redemptions” of shares from such an account less than 90 days (or one year, as applicable) after purchase. “Qualified redemptions” include redemptions for higher education purposes for the account beneficiary and redemptions made upon death or disability. The July 2005 amendments also provide that an employee may, for purposes of the rule limiting the number of trades per calendar quarter in an employee’s personal account to a maximum of 10, count all trades of the same security in the same direction (all buys or all sells) over a period of five consecutive business days as a single trade.

The July 2005 amendments were incorporated into a restated Code of Ethics dated December 2005 (filed as an exhibit hereto).

Item 3. Audit Committee Financial Expert:

The Funds' Audit and Compliance Committee is comprised solely of Trustees who are "independent" (as such term has been defined by the Securities and Exchange Commission ("SEC") in regulations implementing Section 407 of the Sarbanes-Oxley Act (the "Regulations")). The Trustees believe that each of the members of the Audit and Compliance Committee also possess a combination of knowledge and experience with respect to financial accounting matters, as well as other attributes, that qualify them for service on the Committee. In addition, the Trustees have determined that all members of the Funds' Audit and Compliance Committee meet the financial literacy requirements of the New York Stock Exchange's rules and that Mr. Patterson, Mr. Stephens and Mr. Hill qualify as "audit committee financial experts" (as such term has been defined by the Regulations) based on their review of their pertinent experience and education. Certain other Trustees, although not on the Audit and Compliance Committee, would also qualify as "audit committee financial experts." The SEC has stated that the designation or identification of a person as an audit committee financial expert pursuant to this Item 3 of Form N-CSR does not impose on such person any duties, obligations or liability that are greater than the duties, obligations and liability imposed on such person as a member of the Audit and Compliance Committee and the Board of Trustees in the absence of such designation or identification.

Item 4. Principal Accountant Fees and Services:

The following table presents fees billed in each of the last two fiscal years for services rendered to the fund by the fund’s independent auditor:

Fiscal		Audit-
year	Audit	Related	Tax	All Other
ended	Fees	Fees	Fees	Fees
June 30, 2006	$127,390*	$--	$30,846	$ -
June 30, 2005	$113,776*	$--	$21,510	$4,088

* Includes fees of $5,878 and $7,463 billed by the fund’s independent auditor to the fund for audit procedures necessitated by regulatory and litigation matters for the fiscal years ended June 30, 2006 and June 30, 2005, respectively. These fees were reimbursed to the fund by Putnam Investment Management, LLC (“Putnam Management”).

For the fiscal years ended June 30, 2006 and June 30, 2005, the fund’s independent auditor billed aggregate non-audit fees in the amounts of $290,521 and $215,922 respectively, to the fund, Putnam Management and any entity controlling, controlled by or under common control with Putnam Management that provides ongoing services to the fund.

Audit Fees represent fees billed for the fund’s last two fiscal years.

Audit-Related Fees represent fees billed in the fund’s last two fiscal years for services traditionally performed by the fund’s auditor, including accounting consultation for proposed transactions or concerning financial accounting and reporting standards and other audit or attest services not required by statute or regulation.

Tax Fees represent fees billed in the fund’s last two fiscal years for tax compliance, tax planning and tax advice services. Tax planning and tax advice services include assistance with tax audits, employee benefit plans and requests for rulings or technical advice from taxing authorities.

All Other Fees represent fees billed for services relating to an analysis of recordkeeping fees.

Pre-Approval Policies of the Audit and Compliance Committee. The Audit and Compliance Committee of the Putnam funds has determined that, as a matter of policy, all work performed for the funds by the funds’ independent auditors will be pre-approved by the Committee itself and thus will generally not be subject to pre-approval procedures.

The Audit and Compliance Committee also has adopted a policy to pre-approve the engagement by Putnam Management and certain of its affiliates of the funds’ independent auditors, even in circumstances where pre-approval is not required by applicable law. Any such requests by Putnam Management or certain of its affiliates are typically submitted in writing to the Committee and explain, among other things, the nature of the proposed engagement, the estimated fees, and why this work should be performed by that particular audit firm as opposed to another one.

The following table presents fees billed by the fund’s independent auditor for services required to be approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X.

Fiscal	Audit-		All	Total
year	Related	Tax	Other	Non-Audit
ended	Fees	Fees	Fees	Fees
June 30,
2006	$ -	$ 138,160	$ -	$ -
June

30, 2005  $ -  $ -  $ -  $ - 

Item 5. Audit Committee of Listed Registrants

Not applicable

Item 6. Schedule of Investments:

The registrant’s schedule of investments in unaffiliated issuers is included in the report to shareholders in Item 1 above.

Item 7. Disclosure of Proxy Voting Policies and Procedures For Closed-End ManagementInvestment Companies:

Not applicable

Item 8. Portfolio Managers of Closed-End Investment Companies

Not Applicable

Item 9. Purchases of Equity Securities by Closed-End Management Investment Companies andAffiliated Purchasers:

Not applicable

Item 10. Submission of Matters to a Vote of Security Holders:

Not applicable

Item 11. Controls and Procedures:

(a) The registrant's principal executive officer and principal financial officer have concluded, based on their evaluation of the effectiveness of the design and operation of the registrant's disclosure controls and procedures as of a date within 90 days of the filing date of this report, that the design and operation of such procedures are generally effective to provide reasonable assurance that information required to be disclosed by the registrant in this report is recorded, processed, summarized and reported within the time periods specified in the Commission's rules and forms.

(b) Changes in internal control over financial reporting: Not applicable

Item 12. Exhibits:

(a)(1) The Code of Ethics of The Putnam Funds, which incorporates the Code of Ethics of Putnam Investments, is filed herewith.

(a)(2) Separate certifications for the principal executive officer and principal financial officer of the registrant as required by Rule 30a-2(a) under the Investment Company Act of 1940, as amended, are filed herewith.

(b) The certifications required by Rule 30a-2(b) under the Investment Company Act of 1940, as amended, are filed herewith.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Putnam International Equity Fund

By (Signature and Title):

/s/Michael T. Healy
Michael T. Healy
Principal Accounting Officer

Date: August 28, 2006

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title):

/s/Charles E. Porter
Charles E. Porter
Principal Executive Officer

Date: August 28, 2006

By (Signature and Title):
/s/Steven D. Krichmar
Steven D. Krichmar
Principal Financial Officer

Date: August 28, 2006

EX-99.CERT

CertificationsI, Charles E. Porter, a Principal Executive Officer of the funds listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on Attachment A:

2. Based on my knowledge, each report does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by each report;

3. Based on my knowledge, the financial statements, and other financial information included in each report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in each report;

4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a) designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which each report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c) evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of each report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant's other certifying officer and I have disclosed to each registrant's auditors and the audit committee of each registrant's board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect each registrant's ability to record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other employees who have a significant role in each registrant's internal control over financial reporting.

Date: August 24, 2006
/s/ Charles E. Porter
_______________________
Charles E. Porter
Principal Executive Officer

Certifications

I, Steven D. Krichmar, the Principal Financial Officer of the funds listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on Attachment A:

2. Based on my knowledge, each report does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by each report;

3. Based on my knowledge, the financial statements, and other financial information included in each report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in each report;

4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a) designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which each report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c) evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of each report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant's other certifying officer and I have disclosed to each registrant's auditors and the audit committee of each registrant's board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect each registrant's ability to record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other employees who have a significant role in each registrant’s internal control over financial reporting.

Date: August 24, 2006
/s/ Steven D. Krichmar
_______________________
Steven D. Krichmar
Principal Financial Officer

Attachment A
June 30, 2006

057	Putnam Europe Equity Fund
841	Putnam International Equity Fund
852	Putnam New Opportunities Fund
2HF	Putnam Small Cap Growth Fund
2CE	Putnam International Growth & Income Fund
377	Putnam Discovery Growth Fund
2PX	Putnam VT American Government Income Fund
2TP	Putnam VT Capital Appreciation Fund
23K	Putnam VT Capital Opportunities Fund
2TJ	Putnam VT Discovery Growth Fund
961	Putnam VT Diversified Income Fund
23N	Putnam VT Equity Income Fund
2IS	Putnam VT The George Putnam Fund of Boston
070	Putnam VT Global Asset Allocation Fund
016	Putnam VT Global Equity Fund
066	Putnam VT Growth and Income Fund
2PU	Putnam VT Growth Opportunities Fund
2IW	Putnam VT Health Sciences Fund
067	Putnam VT High Yield Fund
068	Putnam VT Income Fund
2DO	Putnam VT International Equity Fund
2DN	Putnam VT International Growth and Income Fund
2DP	Putnam VT International New Opportunities Fund
2IO	Putnam VT Investors Fund
23H	Putnam VT Mid Cap Value Fund
069	Putnam VT Money Market Fund
098	Putnam VT New Opportunities Fund
2DR	Putnam VT New Value Fund
2IP	Putnam VT OTC & Emerging Growth Fund
2LA	Putnam VT Research Fund
2MJ	Putnam VT Small Cap Value Fund
152	Putnam VT Utilities Growth and Income Fund
2DQ	Putnam VT Vista Fund
065	Putnam VT Voyager Fund

EX-99.906 CERT

Section 906 CertificationsI, Charles E. Porter, a Principal Executive Officer of the Funds listed on Attachment A, certify that, to my knowledge:
1. The form N-CSR of the Funds listed on Attachment A for the period ended June 30, 2006, fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on Attachment A for the period ended June 30, 2006 fairly presents, in all material respects, the financial condition and results of operations of the Funds listed on Attachment A.

Date: August 24, 2006

/s/ Charles E. Porter
______________________
Charles E. Porter
Principal Executive Officer

Section 906 CertificationsI, Steven D. Krichmar, a Principal Financial Officer of the Funds listed on Attachment A, certify that, to my knowledge:
1. The form N-CSR of the Funds listed on Attachment A for the period ended June 30, 2006 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on Attachment A for the period ended June 30, 2006 fairly presents, in all material respects, the financial condition and results of operations of the Funds listed on Attachment A.

Date: August 24, 2006

/s/ Steven D. Krichmar
______________________
Steven D. Krichmar
Principal Financial Officer

Attachment A
June 30, 2006

057	Putnam Europe Equity Fund
841	Putnam International Equity Fund
852	Putnam New Opportunities Fund
2HF	Putnam Small Cap Growth Fund
2CE	Putnam International Growth & Income Fund
377	Putnam Discovery Growth Fund
2PX	Putnam VT American Government Income Fund
2TP	Putnam VT Capital Appreciation Fund
23K	Putnam VT Capital Opportunities Fund
2TJ	Putnam VT Discovery Growth Fund
961	Putnam VT Diversified Income Fund
23N	Putnam VT Equity Income Fund
2IS	Putnam VT The George Putnam Fund of Boston
070	Putnam VT Global Asset Allocation Fund
016	Putnam VT Global Equity Fund
066	Putnam VT Growth and Income Fund
2PU	Putnam VT Growth Opportunities Fund
2IW	Putnam VT Health Sciences Fund
067	Putnam VT High Yield Fund
068	Putnam VT Income Fund
2DO	Putnam VT International Equity Fund
2DN	Putnam VT International Growth and Income Fund
2DP	Putnam VT International New Opportunities Fund
2IO	Putnam VT Investors Fund
23H	Putnam VT Mid Cap Value Fund
069	Putnam VT Money Market Fund
098	Putnam VT New Opportunities Fund
2DR	Putnam VT New Value Fund
2IP	Putnam VT OTC & Emerging Growth Fund
2LA	Putnam VT Research Fund
2MJ	Putnam VT Small Cap Value Fund
152	Putnam VT Utilities Growth and Income Fund
2DQ	Putnam VT Vista Fund
065	Putnam VT Voyager Fund

EX-99.CODE ETH

                             THE PUTNAM FUNDS

                              Code of Ethics

Each of The Putnam Funds (the "Funds") has determined to adopt this Code
of Ethics with respect to certain types of personal securities
transactions by officers and Trustees of the Funds which might be deemed
to create possible conflicts of interest and to establish reporting
requirements and enforcement procedures with respect to such
transactions.

I. Rules Applicable to Officers and Trustees Affiliated with Putnam
Investments Trust or Its Subsidiaries

A. Incorporation of Adviser's Code of Ethics.  The provisions of the
Code of Ethics for employees of Putnam Investments Trust and its
subsidiaries (the "Putnam Investments Code of Ethics"), which is
attached as Appendix A hereto, are hereby incorporated herein as the
Funds' Code of Ethics applicable to officers and Trustees of the Funds
who are employees of the Funds or officers, directors or employees of
Putnam Investments Trust or its subsidiaries.  A violation of the Putnam
Investments' Code of Ethics shall constitute a violation of the Funds'
Code.

B. Reports.  Officers and Trustees of each of the Funds who are made
subject to the Putnam Investments' Code of Ethics pursuant to the
preceding paragraph shall file the reports required by the Putnam
Investments' Code of Ethics with the Code of Ethics Officer designated
therein.  A report filed with the Code of Ethics Officer shall be deemed
to be filed with each of the Funds of which the reporting individual is
an officer or Trustee.

C. Review and Reporting.

(1) The Code of Ethics Officer shall cause the reported personal
securities transactions to be compared with completed and contemplated
portfolio transactions of each of the Funds to determine whether a
violation of this Code may have occurred.  Before making any
determination that a violation has been committed by any person, the
Code of Ethics Officer shall give such person an opportunity to supply
additional explanatory material.

(2) If the Code of Ethics Officer determines that a violation of any
provision of this Code has or may have occurred, he shall submit his
written determination, together with any additional explanatory
material, to the Audit and Pricing Committee of the Funds at its next
meeting.

D. Sanctions.  In addition to reporting violations of this Code to the
Audit and Pricing Committee of the Funds as provided in Section I-C(2),
the Code of Ethics officer shall also report to such Committee any
sanctions imposed with respect to such violations.  The Committee
reserves the right to impose such additional sanctions as it deems
appropriate.

II. Rules Applicable to Unaffiliated Trustees

A. Definitions.

(1) "Beneficial ownership" shall be interpreted in the same manner as it
would be in determining whether a person is subject to the provisions of
Section 16 of the Securities Exchange Act of 1934 and the rules and
regulations thereunder.

(2) "Control" means 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.

(3) "Interested Trustee" means a Trustee of a Fund who is an "interested
person" of the Fund within the meaning of the Investment Company Act.

(4) "Purchase or sale of a security" includes, among other things, the
writing of an option to purchase or sell a security.

(5) "Security" shall have the same meaning as that set forth in Section
2(a)(36) of the Investment Company Act (in effect, all securities)
except that it shall not include securities issued by the Government of
the United States or an agency thereof, bankers' acceptances, bank
certificates of deposit, commercial paper and high-quality short-term
debt investments, including repurchase agreements, and shares of
registered open-end investment companies, but shall include any security
convertible into or exchangeable for a security.

(6) "Unaffiliated Trustee" means a Trustee who is not made subject to
the Putnam Investments Code of Ethics pursuant to Part I hereof.

B. Prohibited Purchases and Sales.  No Unaffiliated Trustee of any of
the Funds shall purchase or sell, directly or indirectly, any security
in which he has, or by reason of such transaction acquires, any direct
or indirect beneficial ownership and which to his actual knowledge at
the time of such purchase or sale:

(1) is being considered for purchase or sale by the Fund;

(2) is being purchased or sold by the Fund; or

(3) was purchased or sold by the Fund within the most recent five days
if such person participated in the recommendation to, or the decision
by, Putnam Investment Management to purchase or sell such security for
the Fund.

C. Exempted Transactions.  The prohibitions of Section II-B of this Code
shall not apply to:

(1) purchases or sales of securities effected in any account over which
the Unaffiliated Trustee has no direct or indirect influence or control;

(2) purchases or sales of securities which are non-volitional on the
part of either the Unaffiliated Trustee or the Fund;

(3) purchases of securities which are part of an automatic dividend
reinvestment plan;

(4) purchases of securities effected upon the exercise of rights issued
by an issuer pro rata to all holders of a class of its securities, to
the extent such rights were acquired from such issuer, and sales of such
rights so acquired;

(5) purchases or sales of securities other than those exempted in (1)
through (4) above which do not cause the Unaffiliated Trustee to gain
improperly a personal benefit through his relationship with the Fund and
are only remotely potentially harmful to a Fund because they would be
very unlikely to affect a highly institutional market, and are
previously approved by the Legal and Compliance Liaison Officer of the
Funds, in consultation with the Code of Ethics Officer, which approval
shall be confirmed in writing.

D. Reporting.

(1) Whether or not one of the exemptions listed in Section II-C applies
and except as provided in Section II-C(5), every Unaffiliated Trustee of
a Fund shall file with the Funds' Legal and Compliance Liaison Officer a
report containing the information described in Section II-D(2) of this
Code with respect to purchases or sales of any security in which such
Unaffiliated Trustee has, or by reason of such transaction acquires, any
direct or indirect beneficial ownership, if such Trustee, at the time of
that transaction, knew or, in the ordinary course of fulfilling his
official duties as a Trustee of the Fund, should have known that, during
the 15-day period immediately preceding or after the date of the
transaction by the Trustee:

(a) such security was or is to be purchased or sold by the Fund or

(b) such security was or is being considered for purchase or sale by the
Fund;

provided, however, that an Unaffiliated Trustee shall not be required to
make a report with respect to transactions effected for any account over
which such person does not have any direct or indirect influence or
control.

(2) Every report shall be made not later than 10 days after the end of
the calendar quarter in which the transaction to which the report
relates was effected, and shall contain the following information:

(a) The date of the transaction, the title, the number of shares, the
interest rate and maturity date (if applicable) and the principal amount
of each security involved;

(b) The nature of the transaction (i.e., purchase, sale or any other
type of acquisition or disposition);

(c) The price at which the transaction was effected; and

(d) The name of the broker, dealer or bank with or through whom the
transaction was effected; and

(e) the date that the report is submitted by each Unaffiliated Trustee.

(3) Every report concerning a purchase or sale prohibited under Section
II-B hereof with respect to which the reporting person relies upon one
of the exemptions provided in Section II-C shall contain a brief
statement of the exemption relied upon and the circumstances of the
transaction.

(4) Any such report may contain a statement that the report shall not be
construed as an admission by the person making such report that he has
any direct or indirect beneficial ownership in the security to which the
report relates.

(5) Notwithstanding anything to the contrary contained herein, an
Unaffiliated Trustee who is an "interested person" of the Funds shall
file the reports required by Rule 17j-1(d)(1) under the Investment
Company Act of 1940 with the Code of Ethics Officer of Putnam
Investments.  Such reports shall be reviewed by such Officer as provided
in Section I-C(1) and any related violations shall be reported by him to
the Audit and Pricing Committee as provided in Section I-C(2).  The
Committee may impose such additional sanctions as it deems appropriate.

E. Review and Reporting.

(1) The Legal and Compliance Liaison Officer of the Funds, in
consultation with the Code of Ethics Officer of Putnam Investments,
shall cause the reported personal securities transactions that he
receives pursuant to Section II-D(1) to be compared with completed and
contemplated portfolio transactions of the Funds to determine whether
any transaction ("Reviewable Transactions") listed in Section II-B
(disregarding exemptions provided by Section II-C(1) through (5)) may
have occurred.

(2) If the Legal and Compliance Liaison Officer determines that a
Reviewable Transaction may have occurred, he shall then determine
whether a violation of this Code may have occurred, taking into account
all the exemptions provided under Section II-C.  Before making any
determination that a violation has occurred, the Legal and Compliance
Liaison Officer shall give the person involved an opportunity to supply
additional information regarding the transaction in question.

F. Sanctions.  If the Legal and Compliance Liaison determines that a
violation of this Code has occurred, he shall so advise the Funds' Audit
and Pricing Committee, and provide the Committee with a report of the
matter, including any additional information supplied by such person.
The Committee may impose such sanctions as it deems appropriate.

III. Miscellaneous

A. Amendments to the Putnam Investments' Code of Ethics.  Any amendment
to the Putnam Investments' Code of Ethics shall be deemed an amendment
to Section I-A of this Code effective 30 days after written notice of
such amendment shall have been received by the Chairman of the Funds,
unless the Trustees of the Funds expressly determine that such amendment
shall become effective at an earlier or later date or shall not be
adopted.

B. Records.  The Funds shall maintain records in the manner and to the
extent set forth below, which records may be maintained on microfilm
under the conditions described in Rule 31a-2(f)(1) under the Investment
Company Act and shall be available for examination by representatives of
the Securities and Exchange Commission.

(1) A copy of this Code and any other code which is, or at any time
within the past five years has been, in effect shall be preserved in an
easily accessible place;

(2) A record of any violation of this Code and of any action taken as a
result of such violation shall be preserved in an easily accessible
place for a period of not less than five years following the end of the
fiscal year in which the violation occurs;

(3) A copy of each report made by an officer or Trustee pursuant to this
Code shall be preserved for a period of not less than five years from
the end of the fiscal year in which it is made, the first two years in
an easily accessible place; and

(4) A list of all persons who are, or within the past five years have
been, required to make reports pursuant to this Code shall be maintained
in an easily accessible place.

To the extent any record required to be kept by this section is also
required to be kept by Putnam Investments pursuant to the Putnam
Investments' Code of Ethics, Putnam Investments shall maintain such
record on behalf of the Funds as well.

C. Confidentiality.  All reports of securities transactions and any
other information filed with any Fund pursuant to this Code shall be
treated as confidential, but are subject to review as provided herein
and by personnel of the Securities and Exchange Commission.

D. Interpretation of Provisions.  The Trustees may from time to time
adopt such interpretations of this Code as they deem appropriate.

E. Delegation by Chairman.  The Chairman of the Funds may from time to
time delegate any or all of his responsibilities under this Code, either
generally or as to specific instances, to such officer or Trustee of the
Funds as he may designate.

As revised
November 1, 2004

EX-99.CODE ETH

Putnam Investments

Code of Ethics
December 2005

One Post Office Square
Boston, Massachusetts 02109
1-617-292-1000

www.putnam.com

December, 2005

Dear Putnam Employee,

Putnam’s Code of Ethics is an essential component of the “fiduciary mindset” and of our commitment to the maintenance of the highest professional standards. Taking care of other people’s money is a serious responsibility, and we need to ensure that our clients’ interests come first. Firms with a strong fiduciary culture are attractive to clients who are looking for superior money management, and Putnam’s Code is designed to ensure that Putnam preserves that trust.

The rules reflected in the Code are good business practices and were not created simply to meet regulatory standards. If, from time to time, the rules seem burdensome, I ask you to put yourself in the place of our shareholders and clients, who have entrusted us to manage their assets so that they may pursue the goals of saving for retirement or funding their children’s education.

We have also provided a guide to use as quick reference to some of the Code’s key provisions.

If you have any questions or concerns at any time, however, I encourage you to contact one of the members of our Code of Ethics staff in the Legal and Compliance Department.

Ed Haldeman
President and Chief Executive Officer

Table of Contents
Code of Ethics Overview			iii
PUTNAM’S CODE OF ETHICS			vi
DEFINITIONS			vii
SECTION I -- Personal Securities Rules for All Employees			1
Rule	1:	Requirements to Pre-clear	1
Rule	1:	Short-Selling Prohibition	5
Rule	2:	Initial Public Offerings Prohibition	5
Rule	3:	Private Placement Pre-approval Requirements	6
Rule	4:	Trading with Material Non-public Information	6
Rule	5:	No Personal Trading with Client Portfolios	6
Rule	6:	Holding of Putnam Mutual Fund Shares	7
Rule	7:	Putnam Mutual Fund Employee Restrictions	8
Rule	8:	Special Orders	10
Rule	9:	Excessive Trading	10
Rule	1:	Naked Options	10
Rule	1:	Involuntary Transactions	11
Rule	2:	Special Exemptions	11
SECTION II -- Additional Special Rules for Personal Securities Transactions of Access Persons			12
and Certain Investment Professionals
Rule	1:	90-Day Short-Term Rule	12
Rule	2:	7-Day Rule	12
Rule	3:	Blackout Rule	13
Rule	4:	Contra-Trading Rule	14
Rule	5:	No Personal Benefit	15
SECTION III -- General Rules for All Employees			16
Rule	1:	Compliance with All Laws, Regulations, and Policies	16
Rule	2:	Conflicts of Interest	16
Rule	3:	Gifts and Entertainment Policy	16
Rule	4:	Anti-bribery/Kickback Policy	18
Rule	5:	Political Activities, Contributions, Solicitations, and Lobbying Policy	19
Rule	6:	Confidentiality of Putnam Business Information	20
Rule	7:	Roles at Other Entities (Outside Business Affiliations)	20
Rule	8:	Role as Trustee or Fiduciary Outside of Putnam Investments	21
Rule	9:	Investment Clubs	21
Rule	10: Business Negotiations for Putnam Investments		22
Rule	11: Accurate Records		22
Rule	12: Family Members’ Conflict Policy		22
Rule 13: Affiliated Entities			23
Rule	14: Computer System/Network Policies		24
Rule	15: CFA Institute Code of Ethics		24
Rule	16: Privacy Policy		24
Rule	17: Anti-money Laundering Policy		25
Rule	18: Record Retention		25
SECTION IV -- Special Rules for Officers and Employees of Putnam Investments Limited (PIL)			26
SECTION V -- Reporting Requirements			28
Rule	1:	Broker Confirmations and Statements	28
Rule	2:	Access Person – Quarterly Transaction Report	29
Rule	3:	Access Person - Initial/Annual Holdings Report	29
Rule	4:	Certifications	29
Rule	5:	Roles at Other Entities	29
Rule	6:	Reporting of Irregular Activity	30
Rule	7:	Ombudsman	30
SECTION VI -- Education Requirements			31

Rule 1: Distribution of Code	31
Rule 2: Annual Training Requirement	31
SECTION VII -- Compliance and Appeal Procedures	32
SECTION VIII -- Sanctions	34
APPENDIX A: Insider Trading Prohibitions Policy Statement	35
APPENDIX A: DEFINITIONS: Insider Trading	36
APPENDIX A -- SECTION I: Rules Concerning Inside Information	37
Rule 1: Inside Information	37
Rule 2: Material Non-public Information	37
Rule 3: Reporting of Material Non-public Information	37
APPENDIX A -- SECTION II: Overview of Insider Trading	39
APPENDIX B: Policy Statement Regarding Employee Trades in Shares of Putnam Closed-End	43
Funds
APPENDIX C: Contra-Trading Rule Clearance Form	44
APPENDIX D: CFA Institute Code of Ethics and Standards of Professional Conduct	45*
APPENDIX E: Report of Entertainment Form	49
APPENDIX F -- Inducement Policy for Putnam Investments Limited (PIL) Employees	50
APPENDIX G -- Record of Inducement for Putnam Investments Limited (PIL)Employees	52

Code of Ethics Overview

This overview of Putnam’s Code of Ethics is not intended to substitute for a careful reading of the complete document. As a condition of continued employment, every Putnam employee is required to read, understand, and comply with all of the provisions of the Code of Ethics. Additionally, employees are expected to comply with the policies and procedures contained within the Putnam Employee Handbook, which is available online on www.ibenefitcenter.com.

It is the personal responsibility of every Putnam employee to avoid any conduct that could create a conflict, or even the appearance of a conflict, with our fund shareholders or other clients, or do anything that could damage or erode the trust our clients place in Putnam and its employees. This is the spirit of the Code of Ethics. In accepting employment at Putnam, every employee accepts the absolute obligation to comply with the letter and the spirit of the Code of Ethics. Failure to comply with the spirit of the Code of Ethics is just as much a violation of the Code as failure to comply with the written rules of the Code.

The rules of the Code cover activities, including personal securities transactions, of Putnam employees, certain family members of employees, and entities (such as corporations, trusts, or partnerships) that employees may be deemed to control or influence.

Sanctions will be imposed for violations of the Code of Ethics. Sanctions may include monetary fines, bans on personal trading, reductions in salary increases or bonuses, disgorgement of trading profits, suspension of employment, and termination of employment. The proceeds resulting from monetary sanctions will be given to a charity chosen by the Code of Ethics Officer.

Insider trading

Putnam employees are forbidden to buy or sell any security while either Putnam or the employee is in possession of material, non-public information (inside information) concerning the security or the issuer. A violation of Putnam’s insider trading policies may result in criminal and civil penalties, including imprisonment, disgorgement of profits, and substantial fines. An employee aware of or in possession of inside information must report it immediately to the Code of Ethics Officer. (See Appendix A: Overview of Insider Trading).

Conflicts of interest

The Code of Ethics imposes limits on activities of Putnam employees where the activity may conflict with the interests of Putnam or its clients. These include limits on the receipt and solicitation of gifts and on service as a fiduciary for a person or entity outside of Putnam. For example, Putnam employees generally may not accept gifts over $100 in total value in a calendar year from any entity or any supplier of goods or services to Putnam. In addition, a Putnam employee may not serve as a director of any corporation or other entity without prior approval of the Code of Ethics Officer.

Confidentiality

Information about Putnam clients and Putnam investment activity and research is proprietary and confidential and may not be disclosed or used by any Putnam employee outside Putnam without a valid business purpose.

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Putnam mutual funds

All employees and certain family members are subject to a minimum 90-day holding period for shares in Putnam’s open-end mutual funds. This restriction does not apply to Putnam’s money market funds. Except in limited circumstances, all employees must hold Putnam open-end fund shares in accounts at Putnam.

Portfolio managers and others with access to investment information (“Access Persons”) are subject to a minimum one-year holding period for holding Putnam open-end fund shares.

Personal securities trading

Putnam employees may not buy or sell any security for their own account without clearing the proposed transaction in advance. Clearance is facilitated through the Personal Trading Assistant (PTA), the online pre-clearance system for equity securities, and directly with the Code of Ethics Administrator for fixed-income securities and transactions in Putnam closed-end funds. Certain securities are exempted from this pre-clearance requirement (e.g., shares of open-end (not closed-end) mutual funds).

Putnam employees may not buy any securities in an initial public offering or in a private placement, except in limited circumstances when prior written authorization is obtained.

Clearance must be obtained in advance, between 9:00 a.m. and 4:00 p.m. Eastern Time (ET) on the day of the trade. A clearance is valid only for the day it is obtained. Putnam employees are strongly discouraged from engaging in excessive trading for their personal accounts. Employees are prohibited from making more than 10 trades in individual securities each calendar quarter.

Short selling

Putnam employees are prohibited from short selling any security, whether or not it is held in a Putnam client portfolio, although short selling against broad market indexes and “against the box” are permitted. Note, however, that short selling “against the box” or otherwise hedging an investment in shares of Marsh & McLennan (MMC) stock is prohibited.

Confirmations of trading and periodic account statements

All Putnam employees must have their brokers send copies of confirmations and statements of personal securities transactions to the Code of Ethics Administrator. This also applies to members of the immediate family who share the same household as the employee or for whom the employee has investment discretion. Employees must contact the Code of Ethics Administrator to (a) obtain an authorization [407] letter, (b) provide instructions to the broker in establishing a personal brokerage account, and (c) enter a broker account profile into PTA.

Quarterly and annual reporting

Each calendar quarter, Access Persons must report all their securities transactions to the Code of Ethics Officer within 15 days after the end of the quarter. All Access Persons must disclose all personal securities holdings (even those to which pre-clearance may not apply)

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upon commencement of employment, quarterly, and thereafter on an annual basis. You will be notified if these requirements apply to you.

Personal securities transactions by Access Persons and certain investment professionals

The Code imposes several special restrictions on personal securities transactions by Access Persons and certain investment professionals, which are summarized as follows. (Refer to Section II for details):

• 90-Day Short-Term Rule. No Access Person shall purchase and then sell at a profit, or sell and then repurchase at a lower price, any security or related derivative security within 90 calendar days regardless of tax lot election.

• 7-Day Rule. Before a portfolio manager places an order to buy a security for any portfolio he manages, he must sell from his personal account any such security or related derivative security purchased within the preceding seven calendar days, and disgorge any profit from the sale.

• Blackout Rule. No portfolio manager may sell any security or related derivative security for her personal account until seven calendar days after the most recent purchase of that security or related derivative security for any portfolio she manages. No portfolio manager may buy any security or related derivative security for his personal account until seven calendar days after the most recent sale of that security or related derivative security by any portfolio he manages.

Analysts are also subject to the 7-Day and Blackout Rules in connection with a recommendation to buy/outperform or sell/underperform a security.

• Contra-Trading Rule. No portfolio manager may sell out of her personal account any security or related derivative security that is held in any portfolio she manages unless she has received the written approval of an appropriate CIO and the Code of Ethics Officer.

• No portfolio manager may cause a Putnam client to take action for the manager’s personal benefit.

v

PUTNAM’S CODE OF ETHICS

Putnam Investments is required by law to adopt a Code of Ethics. The purposes of the law are to ensure that companies and their employees comply with all applicable laws and to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between the employees of an investment advisor and its clients. By adopting and enforcing a Code of Ethics, we strengthen the trust and confidence reposed in us by demonstrating that at Putnam, client interests come first.

The Code that follows represents a balancing of important interests. On the one hand, as a registered investment advisor, Putnam owes a duty of undivided loyalty to its clients, and must avoid even the appearance of a conflict that might be perceived as abusing the trust they have placed in Putnam. On the other hand, Putnam does not want to prevent conscientious professionals from investing for their own account where conflicts do not exist or that are immaterial to investment decisions affecting Putnam clients.

When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Putnam employees owe a fiduciary duty to Putnam clients. In most cases, this means that the affected employee will be required to forego conflicting personal securities transactions. In some cases, personal investments will be permitted, but only in a manner, which, because of the circumstances and applicable controls, cannot reasonably be perceived as adversely affecting Putnam client portfolios or taking unfair advantage of the relationship Putnam employees have to Putnam clients.

The Code contains specific rules prohibiting defined types of conflicts. Because every potential conflict cannot be anticipated the Code also contains general provisions prohibiting conflict situations. In view of these general provisions, it is critical that any individual who is in doubt about the applicability of the Code in a given situation seeks a determination from the Code of Ethics Officer about the propriety of the conduct in advance. The procedures for obtaining such a determination are described in Section VII of the Code.

It is critical that the Code be strictly observed. Not only will adherence to the Code ensure that Putnam renders the best possible service to its clients, it will help to ensure that no individual is liable for violations of law.

It should be emphasized that adherence to this policy is a fundamental condition of employment at Putnam. Every employee is expected to adhere to the requirements of this Code of Ethics despite any inconvenience that may be involved. Any employee failing to do so may be subject to disciplinary action, including financial penalties and termination of employment, as determined by the Code of Ethics Officer, the Code of Ethics Oversight Committee, or the Chief Executive Officer of Putnam Investments.

vi

DEFINITIONS

The words below are defined specifically for the purpose of Putnam’s Code of Ethics.

Access Persons Each employee will be informed if he or she is considered an Access Person. The Code of Ethics Officer maintains a list of all Access Persons, categorized as follows:

• All employees of Putnam’s Investment Division

• All employees of Global Operations Services

• All employees who have access to My Putnam (unless access is limited to the Wall Street Journal via Factiva)

• All members of Putnam’s Executive Board

• Senior Managing Directors and Managing Directors of the Transfer Agency

• Senior Managing Directors and Managing Directors of Enterprise Services

• Senior Managing Directors and Managing Directors of Putnam Retail Management (PRM) and Putnam Global Institutional Management (PGIM)

• All directors, officers, employees of a registered investment advisor affiliate, i.e., Putnam Investment Management, LLC, (PIM), The Putnam Advisory Company, LLC (PAC), or Putnam Investments Limited (PIL)

• Employees who have certain systems access and who have access to non-public information about any client’s purchase or sale of securities or to information regarding recommendations with respect to such purchases or sales

• Employees who have access to non-public information regarding the portfolio holdings of any Putnam-advised or sub-advised mutual fund

• Others as defined by the Legal and Compliance Department

Code of Ethics Administrator The individual designated by the Code of Ethics Officer to assume responsibility for day-to-day, nondiscretionary administration of this Code. The current Code of Ethics Administrator is Laura Rose, who can be reached at extension 11104.

Code of Ethics Officer The Putnam officer who has been assigned the responsibility of enforcing and interpreting this Code. The Code of Ethics Officer shall be the Chief Compliance Officer or such other person as is designated by the Chief Executive Officer of Putnam Investments. If the Code of Ethics Officer is unavailable, the Deputy Code of Ethics Officer shall act in his stead. The Code of Ethics Officer is Tony Ruys de Perez. The Deputy Code of Ethics Officer is Kathleen Griffin.

Code of Ethics Oversight Committee Has oversight responsibility for administering the Code of Ethics. Members include the Code of Ethics Officer and other members of Putnam’s senior management approved by the Chief Executive Officer of Putnam.

Immediate family Spouse, partner, minor children, or other relatives living in the same household as the Putnam employee.

Narrow-based derivative A future, swap, option, or similar derivative instrument whose return is determined by reference to fewer than 25 underlying issuers. Single stock futures and exchange traded funds based on less than 25 issuers are included.

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Personal Trading Assistant (PTA) The Personal Trading Assistant (PTA) is an internet application designed for employees to manage personal trading activities, such as pre-clearance, reporting, and certifications, in accordance with regulatory requirements and Putnam’s Code of Ethics.

Policy statements The Insider Trading Prohibitions Policy Statement is attached to the Code as Appendix A and the Policy Statement Regarding Employee Trades in Shares of Putnam Closed-End Funds is attached to the Code as Appendix B.

Private placement Any offering of a security not offered to the public and not requiring registration with the relevant securities authorities.

Purchase or sale of a security Any acquisition or transfer of any interest in the security for direct or indirect consideration; this includes the writing of an option. This definition includes any transfer of a security by an employee as a gift to an individual or a charity.

Putnam Any or all of Putnam, LLC and its subsidiaries, any one of which shall be a Putnam company.

Putnam client Any of the Putnam mutual funds, or any advisor, trust, or other client for whom Putnam manages money.

Putnam employee (or employee) Any employee of Putnam.

Restricted list The list established in accordance with Rule 1 of Section I.A.

Security The following instruments are defined as “securities” and require pre-clearance:

• Any type or class of equity or debt security

• Any rights relating to a security, such as warrants and convertible securities

• Closed-end funds

• Any narrow-based derivative

Pre-clearance and reporting is not required (unless otherwise noted) for:

• Currencies, Treasuries (T-bills), and direct and indirect obligations of the U.S. government and its agencies

• Direct and indirect obligations of any member country in the Organization for Economic CoOperation and Development (OECD), commercial paper, certificates of deposit (CDs), repurchase agreements, bankers’ acceptances, and other money market instruments

viii

NOTE:

Excluded from pre-clearance but not from reporting requirements are: Exchange-traded index funds (ETFs) containing a portfolio of securities of 25 or more issuers (e.g., SPDRs, WEBs, QQQs, iShares, HLDRs), commodities, and any option on a broad-based market index or an exchange-traded futures contract or option.

Transaction for a personal account (or personal securities transaction)Securities transactions: (a) for the personal account of any employee; (b) for the account of a member of the immediate family of any employee; (c) for the account of a partnership in which a Putnam employee or immediate family member is a general partner or a partner with investment discretion; (d) for the account of a trust in which a Putnam employee or immediate family member is a trustee with investment discretion; (e) for the account of a closely held corporation in which a Putnam employee or immediate family member holds shares and for which he has investment discretion; and (f ) for any account other than a Putnam client account, which receives investment advice of any sort from the employee or immediate family member, or as to which the employee or immediate family member has investment discretion.

Rule of construction regarding time periods Unless the context indicates otherwise, time periods used in the Code of Ethics shall be measured inclusively, i.e., beginning on the date from which the measurement is made.

EXCEPTIONS

Unless the context indicates otherwise, there will be no exceptions to the rules.

ix

SECTION I -- Personal Securities Rules for All Employees

A. Pre-clearance

Rule 1: Requirements to Pre-clear

No Putnam employee shall purchase or sell for his personal account any security without prior clearance obtained through procedures set forth by the Code of Ethics Officer. Equity securities are pre-cleared through the Personal Trading Assistant (PTA) pre-clearance system (under the @Putnam tab of www.ibenefitcenter.com). Fixed-income securities must be pre-cleared by calling the Code of Ethics Administrator. There are special rules for trading in Putnam closed-end funds (see Appendix B). Subject to the limited exceptions below, no clearance will be granted for securities appearing on the Restricted List. Securities will be placed on the Restricted List in the following circumstances:

(a) When orders to purchase or sell such security have been entered for any Putnam client or the security is being actively considered for purchase for any Putnam client, unless the security is a non-convertible investment-grade (rated at least BBB by S&P or Baa by Moody’s) fixed-income investment;

(b) When such a security is a voting security of a corporation in the banking, savings and loan, communications, or gaming (i.e., casinos) industries, if holdings of Putnam clients in that corporation exceed 7% (for public utilities, the threshold is 4%);

(c) When, in the judgment of the Code of Ethics Officer, other circumstances warrant restricting personal transactions of Putnam employees in a particular security;

(d) When required under the Policy Statement Concerning Insider Trading Prohibitions. (See Appendix A)

Pre-clearance of Marsh & McLennan (MMC) securities All employee trading in MMC securities must be pre-cleared in the Code of Ethics system. MMC securities include stock, options, and any other securities such as debt. Trades in the MMC Employee Stock Purchase Plan and in all Putnam and MMC employee benefit and bonus plans, i.e., reallocating, rebalancing, or exchanging in and out of the 401(k)/Profit/Bonus Plan, etc., are included in this requirement.

Pre-clearance of MMC is required when, for example, you:

• Sell MMC out of the Stock Purchase Plan

• Exchange MMC shares into or out of your 401(k)/Profit Sharing/Bonus Plan

• Reallocate your Putnam fund choices, which results in a buy or sell of MMC from your 401(k)/Profit Sharing/Bonus Plan

• Trade in MMC securities in other accounts held outside Putnam

 Pre-clearance is not required when you:

• Increase/decrease the amount of money that is automatically deducted (systematic plan) from your paycheck and used to purchase MMC shares in your 401(k)/Profit Sharing/Stock Purchase Plan

• Maintain standing instructions to have money deducted (automatic payroll deductions) and want to increase or decrease the percentage allocated, or instruct to reduce it to “0” in your 401(k)/Profit Sharing/Stock Purchase Plan

• Apply for a loan and/or make withdrawals of the stock from your 401(k)/Profit Sharing Plan

1

COMMENTS

All transactions of MMC require pre-clearance in PTA before you contact your broker to trade shares in an outside brokerage account or before contacting Smith Barney to sell shares out of your Stock Purchase Plan. Also, if MMC is one of your choices in the 401(k)/Profit Sharing Plan, all exchanges in/out must be cleared. Even though clearance is not required for Putnam mutual funds, if you do not wish to include MMC shares when rebalancing any of your fund choices, which will result in an automatic exchange of your MMC shares, you must remember to exclude MMC shares prior to submitting your changes. If you are investing online, check the box to exclude MMC; or if you are investing by telephone with a Putnam representative, ask to exclude MMC before rebalancing the funds.

Additional MMC-related policies:

• MMC securities may from time to time be restricted due to the federal laws that govern trading on inside information. All transactions are prohibited during this period.

• Members of the Executive Board of Directors and members of the Chief Financial Officer’s senior staff may not trade in MMC securities during the calendar quarter-end prior to the public announcement of MMC’s earnings.

• Transactions in MMC securities are not subject to the 90-Day Short-Term Rule (applicable to Access Persons only) or to the holding periods that apply to Putnam mutual funds.

IMPLEMENTATION

A. Maintenance of Restricted List. The Restricted List shall be maintained by the Code of Ethics Administrator.

B. Pre-clearance. An employee wishing to trade any equity securities for his personal account shall first obtain clearance through the Personal Trading Assistant (PTA) system. The system may be accessed online either at www.ibenefitcenter.com by clicking on “Employee Essentials” under the @Putnam tab and selecting “Clear personal trade,” or at iworkplace. Employees may pre-clear securities between 9:00 a.m. and 4:00 p.m. ET. Requests to make personal securities transactions may not be made using the system or presented to the Code of Ethics Administrator before 9:00 a.m. or after 4:00 p.m. ET.

Pre-clearance must be made by calling the Code of Ethics Administrator for fixed-income (municipal and corporate bonds, including non-convertible investment-grade bonds (rated BBB by S&P or Baa by Moody’s) and Putnam closed-end funds.

The PTA system will inform the employee whether the security may be traded and whether trading in the security is subject to the “Large Cap” limitation or the “Considered List – Limited Sale Exception.” The response of the pre-clearance system as to whether a security appears on the Restricted List and, if so, whether it is eligible for the exceptions set forth after this Rule shall be final, unless the employee appeals to the Code of Ethics Officer, using the procedure described in Section VII, regarding the request to trade a particular security.

A clearance is only valid for trading on the day it is obtained. Trades in securities listed on Asian or European stock exchanges, however, may be executed within one business day after pre-clearance is obtained.

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If a security is not on the Restricted List, other classes of securities of the same issuer (e.g., preferred or convertible preferred stock) may be on the Restricted List. It is the employee’s responsibility to identify with particularity the class of securities for which permission is being sought for a personal investment.

If the PTA system does not recognize a security, or if an employee is unable to use the system or has any questions with respect to the system or pre-clearance, the employee may consult the Code of Ethics Administrator. The Code of Ethics Administrator shall not have authority to answer any questions about a security other than whether trading is permitted. The response of the Code of Ethics Administrator as to whether a security appears on the Restricted List and, if so, whether it is eligible for any applicable exceptions set forth after this Rule shall be final, unless the employee appeals to the Code of Ethics Officer, using the procedure described in Section VII, regarding the request to trade a particular security.

EXCEPTIONS

A. Large Cap Exemption. If a security appearing on the Restricted List is an equity security for which the issuer has a market capitalization (defined as outstanding shares multiplied by current price per share) of over $5 billion, then upon clearance approval, the Putnam employee may not trade more than 1,000 shares of the security for the day.

B. Considered List – Limited Sale Rule. As the Putnam list of considered securities is broad and inclusive, employees will be permitted to make limited sales but not purchases of securities held in their accounts if trading is blocked solely by the Considered List of securities.

C. Pre-clearing Transactions Effected by Share Subscription. Trades of securities made by subscription rather than on an exchange are limited to issuers having a market capitalization of $5 billion or more and are subject to the 1,000 share limit. The following are procedures to comply with Rule 1 when effecting a purchase or sale of shares by subscription:

• The Putnam employee must pre-clear the trade on the day he or she submits a subscription to the issuer rather than on the actual day of the trade since the actual day of the trade typically will not be known to the employee who submits the subscription. The employee must contact the Code of Ethics Administrator at the time of pre-clearance and will be told whether the purchase is permitted (in the case of a corporation having a market capitalization of $5 billion or more) or not permitted (in the case of a smaller capitalization issuer).

• The subscription for any purchase or sale of shares must be reported on the Access Person’s quarterly personal securities transaction report, noting the trade was accomplished by subscription.

• Because no brokers are involved in the transaction, the confirmation requirement will be waived for these transactions, although the Putnam employee must provide the Legal and Compliance Department with any transaction summaries or statements sent by the issuer.

D. Trades in Approved Discretionary Brokerage Accounts. A transaction does not need to be pre-cleared if it takes place in an account that the Code of Ethics Officer has approved in writing as exempt from the pre-clearance requirement. In the sole discretion of the Code of Ethics Officer, accounts that will be considered for exclusion from the pre-clearance requirement are only those for which an employee’s securities broker or investment advisor has complete discretion (a discretionary account) and the following conditions are met:

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(i) the employee certifies annually in writing that the employee has no influence over the transactions in the discretionary account and is not aware of the transactions in the discretionary account prior to their execution; (ii) the compliance department of the employee’s broker or investment advisor certifies annually in writing that the employee has no influence over the transactions in the discretionary account and is not aware of the transactions in the discretionary account prior to their execution; and (iii) each calendar quarter, the broker or investment advisor sends Putnam’s Code of Ethics Administrator copies of each quarterly statement for the discretionary account. Employees wishing to seek such an exemption must send a written request to the Code of Ethics Administrator.

COMMENTS

• Pre-clearance. Subpart (a) of Rule 1 is designed to avoid the conflict of interest that might occur when an employee trades for his personal account a security that currently is being traded or is likely to be traded for a Putnam client. Such conflicts arise, for example, when the trades of an employee might have an impact on the price or availability of a particular security, or when the trades of the client might have an impact on price to the benefit of the employee. Thus, exceptions involve situations where the trade of a Putnam employee is unlikely to have an impact on the market.

• Regulatory Limits. Owing to a variety of federal statutes and regulations in the banking, savings and loan, communications, and gaming industries, it is critical that accounts of Putnam clients do not hold more than 10% of the voting securities (5% for public utilities) of any issuer in those industries. Subpart (b) of this rule limits employees’ personal trades to sales of shares in these areas because of the risk that the personal holdings of Putnam employees may be aggregated with Putnam holdings. Putnam’s so-called 7% rule will allow the regulatory limits to be observed.

• Options. For the purposes of this Code, options are treated like the underlying security. Thus, an employee may not purchase, sell, or “write” option contracts for a security that is on the Restricted List. The automatic exercise of an options contract (the purchase or writing of which was previously pre-cleared) does not have to be pre-cleared. Note, however, that the purchase or sale of securities obtained through the exercise of options must be pre-cleared.

• Involuntary Transactions. Involuntary personal securities transactions are exempted from the Code. Special attention should be paid to this exemption. (See Section I.D.)

• Tender Offers. This Rule does not prohibit an employee from tendering securities from his personal account in response to any and all tender offers, even if Putnam clients are also tendering securities. If tendering a security in response to a “partial tender offer”, an employee must pre-clear the trade on the day she submits instructions to her broker, and she will be prohibited from trading if Putnam clients are also tendering the same security.

• Gifts of Securities. Pre-clearance is required for securities donated as a gift to a charitable organization or to an individual. Employees are required to provide a gift transfer certificate of the transaction (if produced) to the Code of Ethics Administrator along with an account statement reflecting the gift transaction. Receipt of a securities gift should be reported on the Access Person’s Annual Holdings Report. Employees who receive a securities gift must report the gift to the Code of Ethics Administrator to make the necessary adjustments in PTA.

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B. Prohibited Transactions

Rule 1: Short-Selling Prohibition

Putnam employees are prohibited from short selling any security, whether or not the security is held in a Putnam client portfolio. Employees are prohibited from hedging investments made in securities of MMC.

EXCEPTION

Short selling against broad market indexes (such as the Dow Jones Industrial Average, the NASDAQ index, and the S&P 100 and 500 indexes) and short selling against the box are permitted (except that short selling shares of MMC against the box is not permitted).

Rule 2: Initial Public Offerings Prohibition

No Putnam employee shall purchase any security for her personal account in an initial public offering.

EXCEPTION

Pre-existing Status Exception. A Putnam employee shall not be barred by this Rule or by Rule 1(a) of Section I.A. from purchasing securities for her personal account in connection with an initial public offering of securities by a bank or insurance company when the employee’s status as a policyholder or depositor entitles her to purchase securities on terms more favorable than those available to the general public, in connection with the bank’s conversion from mutual or cooperative form to stock form, or the insurance company’s conversion from mutual to stock form, provided that the employee has had the status entitling her to purchase on favorable terms for at least two years. This exception is only available with respect to the value of bank deposits or insurance policies that an employee owns before the announcement of the initial public offering. This exception does not apply, however, if the security appears on the Restricted List in the circumstances set forth in subparts (b), (c), or (d) of Section I.A., Rule 1.

COMMENTS

• The purpose of this Rule is twofold. First, it is designed to prevent a conflict of interest between Putnam employees and Putnam clients who might be in competition for the same securities in a limited public offering. Second, the Rule is designed to prevent Putnam employees from being subject to undue influence as a result of receiving favors in the form of special allocations of securities in a public offering from broker-dealers who seek to do business with Putnam.

• Purchases of securities in the immediate after-market of an initial public offering are not prohibited, provided they do not constitute violations of other provisions of the Code of Ethics. For example, participation in the immediate after-market as a result of a special allocation from an underwriting group would be prohibited by Section III, Rule 3, concerning gifts and other favors.

• Public offerings subsequent to initial public offerings are not deemed to create the same potential for competition between Putnam employees and Putnam clients because of the pre-existence of a market for the securities.

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Rule 3: Private Placement Pre-approval Requirements

No Putnam employee shall purchase any security for his personal account in a limited private offering or private placement without prior approval of the Code of Ethics Officer. Privately placed limited partnerships are specifically included in this Rule.

COMMENTS

• The purpose of this Rule is to prevent a Putnam employee from investing in securities for his own account pursuant to a limited private offering that could compete with or disadvantage Putnam clients, and to eliminate any incentives Putnam employees might have to favor those who can affect access to limited offerings.

• Exemptions to the prohibition will generally not be granted where the proposed investment relates directly or indirectly to investments by a Putnam client, or where individuals involved in the offering (including the issuers, broker, underwriter, placement agent, promoter, fellow investors, and affiliates of the foregoing) have any prior or existing business relationship with Putnam or a Putnam employee, or where the Putnam employee believes that such individuals may expect to have a future business relationship with Putnam or a Putnam employee.

• An exemption may be granted, subject to reviewing all the facts and circumstances, for investments in:

(a) Pooled investment funds, including hedge funds, subject to the condition that an employee investing in a pooled investment fund would have no involvement in the activities or decision-making process of the fund except for financial reports made in the ordinary course of the fund’s business, and subject to the condition that the hedge fund does not invest significantly in registered investment companies.

(b) Private placements where the investment cannot relate, or be expected to relate, directly or indirectly to Putnam or investments by a Putnam client.

• Employees who apply for an exemption will be expected to disclose to the Code of Ethics Officer in writing all facts and relationships relating to the proposed investment.

• Applications to invest in private placements will be reviewed by the Code of Ethics Oversight Committee. This review will take into account, among other factors, the considerations described in the preceding comments.

Rule 4: Trading with Material Non-public Information

No Putnam employee shall purchase or sell any security for her personal account or for any Putnam client account while in possession of material, non-public information concerning the security or the issuer. Please read Appendix A, Policy Statement Concerning Insider Trading Prohibitions.

Rule 5: No Personal Trading with Client Portfolios

No Putnam employee shall purchase from or sell to a Putnam client any securities or other property for his personal account, nor engage in any personal transaction to which a Putnam client is known to be a party, or in which the transaction may have a significant relationship to any action taken by a Putnam client.

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IMPLEMENTATION

It is the responsibility of every Putnam employee to make inquiry prior to any personal transaction in order to satisfy himself that the requirements of this Rule have been met.

COMMENT

This rule is required by federal law. It does not prohibit a Putnam employee from purchasing any shares of an open-end Putnam fund. The policy with respect to employee trading in Putnam closed-end funds is attached as Appendix B.

Rule 6: Holding of Putnam Mutual Fund Shares

Putnam employees may not hold shares of Putnam open-end U.S. mutual funds other than through accounts maintained at Putnam. Employees placing purchase orders in shares of Putnam open-end funds must place such orders through Putnam and not through an outside broker or other intermediary. Employees redeeming or exchanging shares of Putnam open-end funds must place those orders through Putnam and not through an outside broker or other intermediary. For transfer instructions, contact a Putnam Preferred Client Services (PCS) representative at 1-800-634-1590.

REMINDER

For purposes of this Rule, “employee” includes:

• -Members of the immediate family of a Putnam employee who share the same household as the employee or for whom the Putnam employee has investment discretion (family member);

• -Any trust in which a Putnam employee or family member is a trustee with investment discretion and in which such Putnam employee or any family members are collectively beneficiaries;

• Any closely held entity (such as a partnership, limited liability company, or corporation) in which a Putnam employee and his or her family members hold a controlling interest and with respect to which they have investment discretion; and

• Any account (including any retirement, pension, deferred compensation, or similar account) in which a Putnam employee or family member has a substantial economic interest and over which the Putnam employee or family member exercises investment discretion.

COMMENTS

These requirements also apply to:

• Self-directed IRA accounts holding Putnam fund shares;

• Variable insurance accounts which invest in Putnam Variable Trusts such as the Putnam/Hartford Capital Manager Programs. Employees must designate Putnam Retail Management as the broker of record for all such accounts and disclose these holdings in the PTA system.

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NOTE:

Employees are required to seek permission from the Code of Ethics Officer to hold Putnam funds in variable trusts outside of Putnam.

EXCEPTION

Retirement, pension, deferred compensation, and similar accounts that cannot be legally transferred to Putnam are not subject to the requirement. For example, a spouse of a Putnam employee may have a 401(k)/Profit Sharing Plan with her employer that invests in Putnam funds. Any employee who continues to hold shares in open-end Putnam funds outside of Putnam must notify the Code of Ethics Officer in writing of the account information, provide the reason why the account cannot be transferred to Putnam, and arrange for a quarterly statement of transaction in such account to be sent to the Code of Ethics Administrator.

Rule 7: Putnam Mutual Fund Employee Restrictions

(a) Employees defined in Rule 6 may not, within a 90-calendar day period, make a purchase followed by a sale or a sale followed by a purchase of shares of the same open-end Putnam mutual fund, even if the transactions occur in different accounts.

(b) Employees who are Access Persons may not, within a one-year period, make a purchase followed by a sale or a sale followed by a purchase of shares of the same open-end Putnam mutual fund or of shares of any U.S. registered mutual fund to which Putnam acts as advisor or sub-advisor, even if the transactions occur in different accounts.

(c) All employees are required to link their immediate family members’ accounts holding Putnam mutual funds to comply with the disclosure requirements. These accounts are also subject to the 90-day and one-year rules. To link these accounts, log on to www.ibenefitcenter.com, click on @Putnam, and select Employee Essentials/Linked Mutual Fund Accounts. You are required to confirm the information and will be prompted to add any accounts that you or your family members have that should be linked or delinked based on the definitions outlined.

COMMENTS

This restriction applies across all accounts maintained by an employee as follows:

• An employee who buys shares of an open-end Putnam mutual fund may not sell any shares of the same mutual fund until 90 calendar days have passed, or one year for Access Persons.

Example: If an employee buys shares of a Putnam fund on Day 1 for a retail account and then sells (by exchange) shares of the same fund for his or her 401(k)/Profit Sharing Plan accounts on Day 85, the employee has violated the rule.

Similarly, an employee who sells shares of an open-end Putnam mutual fund may not buy any shares of the same mutual fund until 90 calendar days have passed, or one year for Access Persons.

• The purpose of these blackout period restrictions is to prevent any market timing or the appearance of any market timing activity.

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• This Rule applies to transactions by a Putnam employee in any type of account including retail, IRA, variable annuity, 401(k)/Profit Sharing Plan, and any deferred compensation accounts.

• The minimum sanction for an initial violation of the blackout period will be disgorgement of any profit made on the transaction. Additional sanctions may apply, including termination of employment.

EXCEPTIONS

A. This restriction does not apply to Putnam’s money market funds and Putnam Stable Value Fund.

B. 401(k)/Profit Sharing Plan Contributions and Payroll Deductions: The 90-day or one year restriction is not triggered by the initial allocation of regular employee or employer contributions or forfeitures to an employee’s account under the terms of Putnam employee benefit plans or a Putnam payroll-deduction direct-investment program; later exchanges of these contributions will be subject to either the 90-day or one-year blackout period.

C. Systematic Programs: This restriction does not apply with respect to shares sold or acquired as a result of participation in a systematic program for contributions, withdrawals, or exchanges, provided that an election to participate in any such program and the participation dates of the program may not be changed more often than quarterly after the program is elected by the employee. Access Persons may elect a quarterly or semiannual rebalancing program although it may only be changed on an annual basis.

D. Employee Benefit Plan Withdrawals and Distributions: This restriction does not apply with respect to shares sold for withdrawals, loans, or distributions under the terms of Putnam employee benefit plans.

E. Dividends, Distributions, Mergers, and Share Class Conversions: This restriction does not apply with respect to the acquisition of shares as a result of reinvestment of dividends, distributions, mergers, conversions of share classes, or other similar actions. Subsequent transactions with respect to the shares will be covered.

F. College Savings Program: Redemptions from an employee’s college savings 529 plan to pay for qualified educational expenses for the beneficiary of the account (and redemptions due to death or disability) are exempt from the 90-day and one-year restrictions applicable to Putnam mutual funds. Qualified redemptions include:

• Tuition

• School fees

• Books

• Supplies and equipment required for enrollment

• Room and board

• Death

• Disability

G. Special Situations: In special situations, Putnam’s Code of Ethics Oversight Committee may grant exceptions to the blackout periods as a result of death, disability, or special circumstances (such as personal hardship), all as determined from time to time by the Committee. Employees can request an exception by submitting a written request to the Code of Ethics Officer.

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Rule 8: Special Orders

Good Until Canceled (GTC) Orders and Limit Orders are prohibited.

Any order not executed on the day of pre-clearance must be resubmitted for pre-clearance before being executed on a subsequent day. “Good until canceled” or “limit” orders are prohibited because of the potential failure to pre-clear.

EXCEPTION

Same-day limit orders are permitted.

Rule 9: Excessive Trading

Putnam employees are strongly discouraged from engaging in excessive trading for their personal accounts. Employees are prohibited from making more than 10 trades in individual securities in any given quarter.

EXCEPTION

For the purpose of calculating the number of trades in any quarter, trading the same security in the same direction (buy or sell) over a period of five business days will be counted as one transaction.

All other rules under the Code of Ethics will continue to be applied.

COMMENTS

Although a Putnam employee’s excessive trading may not itself constitute a conflict of interest with Putnam clients, Putnam believes that its clients’ confidence in Putnam will be enhanced and that the likelihood of Putnam achieving better investment skills results for its clients over the long term will be increased if Putnam employees rely on their investment skills, as opposed to their trading skills in transactions for their own account. Moreover, excessive trading by a Putnam employee for his or her own account diverts an employee’s attention from the responsibility of servicing Putnam clients, and increases the possibilities for transactions that are in actual or apparent conflict with Putnam client transactions. Short-term trading is strongly discouraged, and employees are encouraged to take a long-term view.

C. Discouraged Transactions

Rule 1: Naked Options

Putnam employees are strongly discouraged from engaging in writing (selling) naked options for their personal accounts.

Naked option transactions are particularly dangerous, because a Putnam employee may be prevented by the restrictions in this Code of Ethics from covering the naked option at the appropriate time. All employees should keep in mind the limitations on their personal securities trading imposed by this Code when contemplating such an investment strategy. Engaging in naked options transactions on the basis of material, non-public information is prohibited. (See Appendix A, Policy Statement Concerning Insider Trading Prohibitions.)

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D. Exempted Transactions

Rule 1: Involuntary Transactions

Transactions that are involuntary on the part of a Putnam employee are exempt from the prohibitions set forth in Sections I.A., I.B., and I.C.

COMMENTS

This exemption is based on categories of conduct that the Securities and Exchange Commission does not consider “abusive.”

• Examples of involuntary personal securities transactions include:

(a) Sales out of the brokerage account of a Putnam employee as a result of a bona fide margin call, provided that withdrawal of collateral by the Putnam employee within the ten days previous to the margin call was not a contributing factor to the margin call;

(b) Purchases arising out of an automatic dividend reinvestment program of an issuer of a publicly traded security.

• Transactions by a trust in which the Putnam employee (or a member of his immediate family) holds a beneficial interest, but for which the employee has no direct or indirect influence or control with respect to the selection of investments, are involuntary transactions. In addition, these transactions do not fall within the definition of “personal securities transactions.” (See Definitions.)

• A good-faith belief on the part of the employee that a transaction was involuntary will not be a defense to a violation of the Code of Ethics. In the event of confusion as to whether a particular transaction is involuntary, the burden is on the employee to seek a prior written determination of the applicability of this exemption. The procedures for obtaining such a determination appear in Section VII. D.

Rule 2: Special Exemptions

Transactions that have been determined, in writing by the Code of Ethics Officer before the transaction occurs, to be no more than remotely harmful to Putnam clients because the transaction would be very unlikely to affect a highly institutional market, or because the transaction is clearly not related economically to the securities to be purchased, sold, or held by a Putnam client, are exempt from the prohibitions set forth in Sections I.A., I.B., and I.C.

IMPLEMENTATION

An employee may seek an ad hoc exemption under this Rule by following the procedures in Section VII.D.

COMMENTS

• This exemption is also based upon categories of conduct that the Securities and Exchange Commission does not consider “abusive.”

• The burden is on the employee to seek a prior written determination that the proposed transaction meets the standards for an ad hoc exemption set forth in this Rule.

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SECTION II -- Additional Special Rules for Personal Securities Transactions of Access Persons and Certain Investment Professionals

Access Persons include all investment professionals and other employees as defined on page vii.

Rule 1: 90-Day Short-Term Rule

Access Persons may not sell a security at a profit within 90 days of purchase or buy a security at a price below which he or she sold it within the past 90 days.

EXCEPTION

None, unless prior written approval from the Code of Ethics Officer is obtained. Exceptions may be granted on a case-by-case basis when no abuse is involved and the equities of the situation support an exemption. For example, although an Access Person may buy a stock as a long-term investment, that stock may have to be sold involuntarily due to unforeseen activity such as a merger.

IMPLEMENTATION

A. The 90-Day Short-Term Rule applies to all Access Persons, as defined in the Definitions section of the Code.

B. Calculation of whether there has been a profit is based upon the market prices of the securities. The calculation includes commissions and other sales charges.

C. As an example, an Access Person would not be permitted to sell a security at $12 that he purchased within the prior 90 days for $10. Similarly, an Access Person would not be permitted to purchase a security at $10 that she had sold within the prior 90 days for $12.

COMMENTS

• The prohibition against short-term trading profits by Access Persons is designed to minimize the possibility that they will capitalize inappropriately on the market impact of trades involving a client portfolio about which they might possibly have information.

• Although Chief Investment Officers, portfolio managers, and analysts may sell securities at a profit within 90 days of purchase in order to comply with the requirements of the 7-Day Rule applicable to them (described below), the profit will have to be disgorged to charity under the terms of the 7-Day Rule.

Certain Investment Professionals

Rule 2: 7-Day Rule

(a) Before a portfolio manager (including a Chief Investment Officer with respect to an account he manages) places an order to buy a security for any Putnam client portfolio that he manages, he must sell that security or related derivative security if he has purchased it in his personal account within the preceding seven calendar days.

(b) Analysts: Before an analyst makes a purchase or an outperform recommendation for a security (including designation of a security for inclusion in the portfolio of Putnam Research Fund), he must sell that security or related derivative security if he has purchased it in his personal account within the preceding seven calendar days.

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COMMENTS

• This Rule applies to portfolio managers (including Chief Investment Officers with respect to accounts they manage) in connection with any purchase, no matter how small, in any client account managed by that portfolio manager or CIO (even so-called “clone accounts”). In particular, it should be noted that the requirements of this Rule also apply with respect to purchases in client accounts, including “clone accounts,” resulting from “cash flows.” To comply with the requirements of this Rule, it is the responsibility of each portfolio manager or CIO to be aware of the placement of all orders for purchases of a security by client accounts that he or she manages for seven days following the purchase of that security for his or her personal account.

• An investment professional who must sell securities to be in compliance with the 7-Day Rule must absorb any loss and disgorge to charity any profit resulting from the sale. The recipient charity will be chosen by the Code of Ethics Officer.

• This Rule is designed to avoid even the appearance of a conflict of interest between an investment professional and a Putnam client. A greater burden is placed on these professionals given their positions in the organization. Transactions executed for the employee’s personal account must be conducted in a manner consistent with the Code of Ethics and in such a manner as to avoid any actual or perceived conflict of interest or any abuse of the employee’s position of trust and responsibility.

• “Portfolio manager” is used in this Section as a functional label, and is intended to cover any employee with authority to authorize a trade on behalf of a Putnam client, whether or not such employee bears the title “portfolio manager.” “Analyst” is also used in this Section as a functional label, and is intended to cover any employee who is not a portfolio manager but who may make recommendations regarding investments for Putnam clients.

Rule 3: Blackout Rule

(a) Portfolio Managers: No portfolio manager (including Chief Investment Officers with respect to accounts they manage) shall: (i) sell any security or related derivative security for her personal account until seven calendar days have elapsed since the most recent purchase of that security or related derivative security by any Putnam client portfolio she manages or co-manages; or (ii) purchase any security or related derivative security for her personal account until seven calendar days have elapsed since the most recent sale of that security or related derivative security from any Putnam client portfolio that she manages or co-manages.

(b) Analysts: No analyst shall: (i) sell any security or related derivative security for his personal account until seven calendar days have elapsed since his most recent buy or outperform recommendation for that security or related derivative security (including designation of a security for inclusion in the portfolio of Putnam Research Fund); or (ii) purchase any security or related derivative security for his personal account until seven calendar days have elapsed since his most recent sell or underperform recommendation for that security or related derivative security (including the removal of a security from the portfolio of Putnam Research Fund).

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COMMENTS

• This Rule applies to portfolio managers (including Chief Investment Officers with respect to accounts they manage) in connection with any purchase, no matter how small, in any client account managed by that portfolio manager or CIO (even clone accounts). In particular, it should be noted that the requirements of this rule also apply with respect to transactions in client accounts, including clone accounts, resulting from cash flows. In order to comply with the requirements of this Rule, it is the responsibility of each portfolio manager and CIO to be aware of all transactions in a security by client accounts that he or she manages that took place within the seven days preceding a transaction in that security for his or her personal account.

• This Rule is designed to prevent a Putnam portfolio manager or analyst from engaging in personal investment conduct that appears to be counter to the investment strategy she is pursuing or recommending on behalf of a Putnam client.

Rule 4: Contra-Trading Rule

(a) Portfolio Managers: No portfolio manager shall, without prior clearance and written approval, sell out of his personal account securities or related derivative securities held in any Putnam client portfolio that he manages or co-manages.

(b) Chief Investment Officers: No Chief Investment Officer shall, without prior clearance and written approval, sell out of his personal account securities or related derivative securities held in any Putnam client portfolio managed in his investment group.

IMPLEMENTATION

A. Individuals Authorized to Give Approval. Prior to engaging in any such sale, a portfolio manager shall seek written approval of the proposed sale. In the case of a portfolio manager, prior written approval of the proposed sale shall be obtained from a Chief Investment Officer to whom he reports or, in his absence, another Chief Investment Officer. In the case of a Chief Investment Officer, prior written approval of the proposed sale shall be obtained from another Chief Investment Officer. In addition to the foregoing, prior written approval must also be obtained from the Code of Ethics Officer.

B. Contents of Written Approval. In every instance, the written approval form attached as Appendix C (or such other form as the Code of Ethics Officer shall designate) shall be used. The written approval should be signed by the Chief Investment Officer giving approval and dated when such approval was given, and shall state, briefly, the reasons why the trade was allowed and why the investment conduct pursued by the portfolio manager or Chief Investment Officer was deemed inappropriate for the Putnam client account controlled by the individual seeking to engage in the transaction for his personal account. Such written approval shall be sent by the Chief Investment Officer approving the transaction to the Code of Ethics Officer, for her approval, within 24 hours or as promptly as circumstances permit. Approvals obtained after a transaction has been completed, or while it is in process, will not satisfy the requirements of this Rule.

COMMENT

This Rule, like Rule 3 of this section, is designed to prevent a Putnam portfolio manager from engaging in personal investment conduct that appears to be counter to the investment strategy that he is pursuing on behalf of a Putnam client.

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Rule 5: No Personal Benefit

No portfolio manager shall cause, and no analyst shall recommend, a Putnam client to take action for the portfolio manager’s or analyst’s own personal benefit.

COMMENTS

• A portfolio manager who trades in, or an analyst who recommends, particular securities for a Putnam client account in order to support the price of securities in his personal account, or who “front runs” a Putnam client order is in violation of this Rule. Portfolio managers and analysts should be aware that this Rule is not limited to personal transactions in securities (as that word is defined in the Definitions section). Thus, a portfolio manager or analyst who front runs a Putnam client purchase or sale of obligations of the U.S. government is in violation of this Rule. U.S. government obligations are excluded from the definition of security.

• This Rule is not limited to instances when a portfolio manager or analyst has malicious intent. It also prohibits conduct that creates an appearance of impropriety. Portfolio managers and analysts who have questions about whether proposed conduct creates an appearance of impropriety should seek a prior written determination from the Code of Ethics Officer, using the procedures described in Section VII.C.

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SECTION III -- General Rules for All Employees

Rule 1: Compliance with All Laws, Regulations, and Policies

All employees must comply with applicable laws and regulations as well as company policies. This includes tax, anti-trust, political contribution, and international boycott laws. In addition, no employee at Putnam may engage in fraudulent conduct of any kind.

COMMENTS

• Putnam may report to the appropriate legal authorities conduct by Putnam employees that violates this Rule.

• It should also be noted that the U.S. Foreign Corrupt Practices Act makes it a criminal offense to make a payment or offer of payment to any non-U.S. governmental official, political party, or candidate to induce that person to affect any governmental act or decision, or to assist Putnam’s obtaining or retaining business.

Rule 2: Conflicts of Interest

No Putnam employee shall conduct herself in a manner that is contrary to the interests of, or in competition with, Putnam or a Putnam client, or that creates an actual or apparent conflict of interest with a Putnam client.

COMMENTS

• This Rule is designed to recognize the fundamental principle that Putnam employees owe their chief duty and loyalty to Putnam and Putnam clients.

• It is expected that a Putnam employee who becomes aware of an investment opportunity that she believes is suitable for a Putnam client whom she services will present it to the appropriate portfolio manager prior to taking advantage of the opportunity herself.

Rule 3: Gifts and Entertainment Policy

No Putnam employee shall accept anything of material value from any broker-dealer, financial institution, corporation, or other entity; any existing or prospective supplier of goods or services with a business relationship to Putnam; or any company or other entity whose securities are held in or are being considered as investments for the Putnam funds, or any other client account. Included are gifts, favors, preferential treatment, special arrangements, or access to special events.

COMMENTS

This Rule is intended to permit the acceptance of only proper types of customary and limited business amenities.

A Putnam employee may not, under any circumstances, accept anything that could create the appearance of a conflict of interest. For example, acceptance of any consideration is prohibited if it would create the appearance of a reward or inducement for conducting Putnam business either with the person providing the gift or his employer.

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IMPLEMENTATION

A. Gifts. An employee may not accept gifts with an aggregate value of more than $100 in any year from any one source, i.e., entity or firm. Any Putnam employee who is offered or receives an item exceeding $100 in value must report the details to the Code of Ethics Officer and surrender or return the gift. Any entertainment event provided to an employee where the host is not in attendance is treated as a gift and is subject to the $100 per year per source limit.

B. Entertainment. Putnam’s rules are designed to permit reasonable, ordinary business entertainment, but prohibit any events that may be perceived as extravagant or that involve lavish expenditures.

1. Occasional lunches, dinners, cocktail parties, or comparable gatherings conducted for business purposes are permitted.

For example, occasional attendance at group functions sponsored by sell-side firms is permitted where the function relates to investments or other business activity. Occasional attendance at these functions is not required to be counted against the limits described in section (B)(2) below.

2. Other entertainment events, such as sporting events, theater, movies, concerts, or other forms of entertainment conducted for business purposes, are permitted only under the following conditions:

(i)The host must be present for the event.

(ii)The location of the event must be in the metropolitan area in which the office of the employee is located.

(iii)Spouses or other family members of the employee may not attend the entertainment event or any meals before or after the entertainment event.

(iv)The value of the entertainment event provided to the employee may not exceed $150, not including the value of any meals that may be provided to the employee before or after the event.

Acceptance of entertainment events that have a market value materially exceeding the face value of the entertainment, which includes, for example, attendance at sporting event playoff games, is prohibited. This prohibition applies even if the face value of tickets to the events is $150 or less or if the Putnam employee offers to pay for the tickets. If there is any ambiguity about whether to accept an entertainment event in these circumstances, please consult the Code of Ethics Officer.

(v)The employee may not accept entertainment events under this provision in section (B)(2) more than six times a year and not more than two times in any year from any single source.

(vi)The Code of Ethics Officer may grant exceptions to these rules. For example, it may be appropriate for an employee attending a legitimate conference in a location away from the office to attend a business entertainment event in that location. All exceptions must be approved in advance by written request to the Code of Ethics Officer.

3. Any employee attending any entertainment event under the provision in sections (B)(1) or (B)(2) above must file a Report of Entertainment Form (attached as Appendix E) with the Code of Ethics Officer within 10 business days following the date of the entertainment event. Failure to file the notice is a violation of the Code of Ethics.

Planned absences, i.e., vacations, leaves (other than certain medical leaves), or business trips are not valid excuses for providing late reports. Failure to meet the deadline violates the Code’s rules and sanctions may be imposed.

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4. Meals and entertainment that are part of the regular program at an investment conference (i.e., open to all participants) are not subject to the limits of section (B)(2) above.

C. The following items are prohibited:

1. Any entertainment event attendance that would reflect badly on Putnam as a firm of the highest fiduciary and ethical standards. For example, events involving adult entertainment or gambling must be avoided.

2. Entertainment involving travel away from the metropolitan area in which the employee is located. Even if an exception is granted as discussed in section (B)(2)(vi) above, payment by a third party of the cost of transportation to a location outside the employee’s metropolitan area, lodging while in another location, and any meals not specifically approved by the Code of Ethics officer are prohibited.

3. Personal loans to a Putnam employee on terms more favorable than those generally available for comparable credit standing and collateral.

4. Preferential brokerage or underwriting commissions or spreads or allocations of shares or interests in an investment for the personal account of a Putnam employee.

5. Cash or cash equivalents.

D. As with any of the provisions of the Code of Ethics, a sincere belief by the employee that he was acting in accordance with the requirements of this Rule will not satisfy his obligations under the Rule. Therefore, an employee who is in doubt concerning the propriety of any gift or favor should seek a prior written determination from the Code of Ethics Officer, as provided in Section VII.C.

E. No Putnam employee may solicit any gift or entertainment from any person, even if the gift or entertainment, if unsolicited, would be permitted.

F. The Rule does not prohibit employees on business travel from using local transportation and arrangements customarily supplied by brokers or similar entities. For example, it is customary for brokers in developing markets to make local transportation arrangements. These arrangements are permitted so long as the expense of lodging and air travel are paid by Putnam.

G. Putnam Retail Management (PRM) employees are subject to additional NASD rules on gifts and entertainment which can be found in the PRM compliance manual.

Rule 4: Anti-bribery/Kickback Policy

No Putnam employee shall pay, offer, or commit to pay any amount of consideration which might be, or appear to be, a bribe or kickback in connection with Putnam’s business.

COMMENT

Although the Rule does not specifically address political contributions (described in Rule 5), Putnam employees should be aware that it is against corporate policy to use company assets to fund political contributions of any sort, even where such contributions may be legal. No Putnam employee should offer or agree to make any political contributions (including political dinners and similar fundraisers) on behalf of Putnam, and no employee will be reimbursed by Putnam for such contributions made by the employee personally.

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Rule 5: Political Activities, Contributions, Solicitations, and Lobbying Policy

A. Corporate Contributions and Solicitations. Political activities of corporations such as Putnam are highly regulated, and corporate political contributions are largely prohibited. Accordingly, no contributions may be made with Putnam corporate funds to any political party or campaign, whether directly or by reimbursement of such a contribution, unless pre-approved by the Code of Ethics Officer. Employee contributions to any pending or proposed client of Putnam, regardless of whether the employee will seek reimbursement from Putnam for such contributions, must be pre-approved by the Code of Ethics Officer. Donations of Putnam property and of employee time when working for Putnam are prohibited. No Putnam employee may make any solicitation for, or endorsement of, any campaign or candidate using Putnam letterhead, referencing Putnam, or while on Putnam business.

B. Employee Personal Political Contributions. Employees are free to engage in political activities as long as they do not use Putnam assets, or state or imply that Putnam is involved in a campaign. Employees are subject to three restrictions as follows:

1. - -Some states and localities have laws that prohibit employees from making political contributions to candidates for state and local office if their employer has an investment management contract with, or is seeking one from, the state or locality. Accordingly, Putnam employees must pre-clear with the Code of Ethics Officer any contributions to candidates for any of the following offices:

• The office of State Treasurer of Connecticut or Vermont

• State or local offices in California, New Jersey, or Ohio

• Any local office in the city of Houston, Texas

2. - -Contributions to state and local officials with whom Putnam has a business relationship or from whom is seeking a business relationship must be pre-cleared with the Code of Ethics Officer.

3. - -Certain employees at PRM involved in the CollegeAdvantage program are restricted from making contributions to candidates for offices in Ohio under the rules of the Municipal Securities Rulemaking Board. These employees are separately identified and informed by Putnam’s Compliance Department of applicable requirements.

C. Government Official. Employees must obtain pre-approval from the Code of Ethics Officer prior to providing any gift (including meals, entertainment, transportation, or lodging) to any government official or employee.

D. Lobbying. Federal and state law imposes limits and registration requirements on efforts by individuals and companies to influence the passage of legislation or to obtain business from governments. Accordingly, Putnam employees should not engage in any lobbying activities without approval from Putnam’s Director of Government Relations. Lobbying does not include solicitation of investment management business through the ordinary course of business, such as responding to a Request For Proposal (RFP).

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COMMENTS

• Putnam has established a political action committee (PAC) that contributes to worthy candidates for political office. Any request received by a Putnam employee for a political contribution must be directed to Putnam’s Legal and Compliance Department.

• This Rule prohibits solicitation on personal letterhead by Putnam employees except as approved by the Code of Ethics Officer.

• Certain officers and employees of Putnam Retail Management (PRM) and other employees involved in Putnam’s College Advantage Section 529 Plan with Ohio Tuition Trust Authority are subject to special rules on political contributions. For questions on these requirements, please call the Code of Ethics Officer.

Rule 6: Confidentiality of Putnam Business Information

No unauthorized disclosure may be made by any employee or former employee of any trade secrets or proprietary information of Putnam or of any confidential information. No information regarding any Putnam client portfolio, actual or proposed securities trading activities of any Putnam client, or Putnam research shall be disclosed outside the Putnam organization unless doing so has a valid business purpose and is in accord with relevant procedures established by Putnam relating to such disclosures.

COMMENT

All information about Putnam and Putnam clients is strictly confidential. Putnam research information should not be disclosed without proper approval and never for personal gain.

Rule 7: Roles at Other Entities (Outside Business Affiliations)

No Putnam employee shall serve as employee, officer, director, trustee, or general partner of a corporation or entity other than Putnam, without prior written approval of the Code of Ethics Officer. Requests for a role at a publicly traded company are especially disfavored and are closely reviewed. Permission will be granted only in extenuating circumstances.

COMMENTS

If the request is approved, the employee must enter his profile in the Personal Trading Assistant under Disclosures – Outside Business Affiliations.

NASD-licensed employees under PRM also have an obligation to disclose outside business affiliations, new or terminated, with Putnam’s Licensing and Registration Department.

EXCEPTION

Charitable or Non-profit Exception. Putnam employees may serve as an officer, director, or trustee of a charitable or not-for-profit institution, provided that the employee abides by the Code of Ethics and the Policy Statements with respect to any investment activity for which she has any discretion or input as officer, director, or trustee. The pre-clearance and reporting requirements of the Code of Ethics do not apply to the trading activities of such charitable or not-for-profit institutions for which an employee serves as an officer, director, or trustee unless the employee is responsible for day-today portfolio management of the account.

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COMMENTS

• This Rule is designed to ensure that Putnam cannot be deemed an affiliate of any issuer of securities by virtue of service by one of its officers or employees as director or trustee.

• Positions with public companies are especially problematic and will normally not be approved.

• Certain charitable or not-for-profit institutions have assets (such as endowment funds or employee benefit plans) which require prudent investment. To the extent that a Putnam employee (because of her position as officer, director, or trustee of an outside entity) is charged with responsibility to invest such assets prudently, she may not be able to discharge that duty while simultaneously abiding by the spirit of the Code of Ethics and the Policy Statements. Employees are cautioned that they should not accept service as an officer, director, or trustee of an outside charitable or not-for-profit entity where such investment responsibility is involved, without seriously considering their ability to discharge their fiduciary duties with respect to such investments.

Rule 8: Role as Trustee or Fiduciary Outside of Putnam Investments

No Putnam employee shall serve as a trustee, an executor, a custodian, or any other fiduciary, or as an investment advisor or counselor for any account outside Putnam.

EXCEPTIONS

A. Charitable or Religious Exception. Putnam employees may serve as a fiduciary with respect to a religious or charitable trust or foundation, so long as the employee abides by the spirit of the Code of Ethics and the Policy Statements with respect to any investment activity over which he has any discretion or input. The pre-clearance and reporting requirements of the Code of Ethics do not apply to the trading activities of such a religious or charitable trust or foundation unless the employee is responsible for day-to-day portfolio management of the account.

B. Family Trust or Estate Exception. Putnam employees may serve as a fiduciary with respect to a family trust or estate, as long as the employee abides by all of the Rules of the Code of Ethics with respect to any investment activity over which he has any discretion.

COMMENT

The roles permissible under this Rule may carry with them the obligation to invest assets prudently. Once again, Putnam employees are cautioned that they may not be able to fulfill their duties in that respect while abiding by the Code of Ethics and the Policy Statements.

Rule 9: Investment Clubs

No Putnam employee may be a member of any investment club.

COMMENT

This Rule guards against the danger that a Putnam employee may be in violation of the Code of Ethics and the Policy Statements by virtue of his personal securities transactions in or through an entity that is not bound by the restrictions imposed by this Code of Ethics and the Policy Statements. Please note that this restriction also applies to the spouse of a Putnam employee and any relatives of a Putnam employee living in the same household as the employee, as their transactions are covered by the Code of Ethics (see page viii).

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Rule 10: Business Negotiations for Putnam Investments

No Putnam employee may become involved in a personal capacity in consultations or negotiations for corporate financing, acquisitions, or other transactions for outside companies (whether or not held by any Putnam client), nor negotiate nor accept a fee in connection with these activities without obtaining the prior written permission of the Chief Executive Officer of Putnam Investments.

Rule 11: Accurate Records

No employee may create, alter, or destroy (or participate in the creation, alteration, or destruction of) any record that is intended to mislead anyone or to conceal anything that is, or is reasonably believed to be, improper. In addition, all employees responsible for the preparation, filing, or distribution of any regulatory filings or public communications must ensure that such filings or communications are timely, complete, fair, accurate, and understandable.

COMMENTS

• In many cases, this is not only a matter of company policy and ethical behavior but also required by law. Our books and records must accurately reflect the transactions represented and their true nature. For example, records must be accurate as to the recipient of all payments; expense items, including personal expense reports, must accurately reflect the true nature of the expense. No unrecorded fund or asset shall be established or maintained for any reason.

• All financial books and records must be prepared and maintained in accordance with generally accepted accounting principles and Putnam’s existing accounting controls, to the extent applicable.

Rule 12: Family Members’ Conflict Policy

No employee or member of an employee’s immediate family shall have any direct or indirect personal financial interests in companies that do business with Putnam, unless such interest is disclosed and approved by the Code of Ethics Officer. Investment holdings in public companies that are not material to the employee are excluded from this prohibition. The Code also provides more detailed supplemental rules to address potential conflicts of interests that may arise if members of employees’ families are closely involved in doing business with Putnam.

Corporate Purchase of Goods and Services -- Putnam will not acquire goods and services from any firm in which a member of an employee’s immediate family serves as the sales representative in a senior management capacity or has an ownership interest with the supplier firm (excluding normal investment holdings in public companies) without permission from the Director of Procurement and the Code of Ethics Officer. Any employee who is aware of a proposal to purchase goods and services from a firm at which a member of the employee’s immediate family meets one of the previously mentioned conditions must notify the Director of Procurement and the Code of Ethics Officer.

Portfolio Trading -- Putnam will not allocate any trades for a portfolio to any firm that employs a member of an employee’s immediate family as a sales representative to Putnam (in a primary, secondary, or backup role). Any Putnam employee who is aware that an immediate family member serves as a broker-dealer’s sales representative to Putnam should inform the Code of Ethics Officer.

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Definition of Immediate Family -- “Immediate family” of an employee means (1) spouse or partner of the employee, (2) any child, sibling, or parent of an employee and any person married to a child, sibling, or parent of an employee, and (3) any other person who lives in the same household as the employee.

Rule 13: Affiliated Entities

Non-Putnam affiliates (NPAs), listed below in the last comment, provide investment advisory services. No employee shall:

(a) Directly or indirectly seek to influence the purchase, retention or disposition of, or exercise of voting consent, approval, or similar rights with respect to any portfolio security in any account or fund advised by the NPA and not by Putnam;

(b) Transmit any information regarding the purchase, retention or disposition of, or exercise of voting, consent, approval, or similar rights with respect to any portfolio security held in a Putnam or NPA client account to any personnel of the NPA;

(c) Transmit any trade secrets, proprietary information, or confidential information of Putnam to the NPA unless doing so has a valid business purpose and is in accord with any relevant procedures established by Putnam relating to such disclosures;

(d) Use confidential information or trade secrets of the NPA for the benefit of the employee, Putnam, or any other NPA; or

(e) Breach any duty of loyalty to the NPA derived from the employee’s service as a director or officer of the NPA.

COMMENTS

• Sections (a) and (b) of the Rule are designed to help ensure that the portfolio holdings of Putnam clients and clients of the NPA need not be aggregated for purposes of determining beneficial ownership under Section 13(d) of the Securities Exchange Act or applicable regulatory or contractual investment restrictions that incorporate such definition of beneficial ownership. Persons who serve as directors or officers of both Putnam and an NPA should take care to avoid even inadvertent violations of Section (b). Section (a) does not prohibit a Putnam employee who serves as a director or officer of the NPA from seeking to influence the modification or termination of a particular investment product or strategy in a manner that is not directed at any specific securities. Sections (a) and (b) do not apply when a Putnam affiliate serves as an advisor or sub-advisor to the NPA or one of its products, in which case normal Putnam aggregation rules apply.

• As a separate entity, any NPA may have trade secrets or confidential information that it would not choose to share with Putnam. This choice must be respected.

• When Putnam employees serve as directors or officers of an NPA, they are subject to common law duties of loyalty to the NPA, despite their Putnam employment. In general, this means that when performing their duties as NPA directors or officers, they must act in the best interest of the NPA and its shareholders. Putnam’s Legal and Compliance Department will assist any Putnam employee who is a director or officer of an NPA and has questions about the scope of his or her responsibilities to the NPA.

• Entities that are currently non-Putnam affiliates within the scope of this Rule are: Nissay Asset Management Co., Ltd., L.P., Thomas H. Lee Partners, L.P., Ampega Asset Management, GmbH, and PanAgora Asset Management, Inc.

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Rule 14: Computer System/Network Policies

No employee shall use computers, the Internet, e-mail, instant messaging, phones, fax machines and/or the mail service in a manner that is inconsistent with their use as set forth in Putnam’s Employee Handbook. No employee shall introduce a computer virus or computer code that may result in damage to Putnam’s information or computer systems.

COMMENT

Putnam’s policy statements relating to these matters are contained in the Computer System and Network Responsibilities section of the Employment Issues category within the Employee Handbook. The online Employee Handbook is located on www.ibenefitcenter.com.

Rule 15: CFA Institute Code of Ethics

All employees must follow and abide by the spirit of the Code of Ethics and the Standards of Professional Conduct of the CFA Institute. The text of the CFA Institute Code of Ethics and Standards of Professional Conduct are set forth in Appendix D.

Rule 16: Privacy Policy

Except as provided below, no employee may disclose to any outside organization or person any non-public personal information about any individual who is a current or former shareholder of any Putnam retail or institutional fund, or current or former client of a Putnam company. All employees shall follow the security procedures as established from time to time by a Putnam company to protect the confidentiality of all shareholder and client account information.

Except as Putnam’s Legal and Compliance Department may expressly authorize, no employee shall collect any non-public personal information about a prospective or current shareholder of a Putnam fund or prospective or current client of a Putnam company, other than through an account application (or corresponding information provided by the shareholder’s financial representative) or in connection with executing shareholder or client transactions, nor shall any information be collected other than the following: name, address, telephone number, Social Security number, and investment, broker, and transaction information.

EXCEPTIONS

A. Putnam Employees. Non-public personal information may be disclosed to a Putnam employee in connection with processing transactions or maintaining accounts for shareholders of a Putnam fund and clients of a Putnam company, to the extent that access to such information is necessary to the performance of that employee’s job functions.

B. Shareholder Consent Exception. Non-public personal information about a shareholder’s or client’s account may be provided to a non-Putnam organization at the specific request of the shareholder or client or with the shareholder’s or client’s prior written consent.

C. Broker or Advisor Exception. Non-public personal information about a shareholder’s or client’s account may be provided to the shareholder’s or client’s broker of record.

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D. Third-Party Service Provider Exception. Non-public personal information may be disclosed to a service provider that is not affiliated with a Putnam fund or Putnam company only when such disclosure is necessary for the service provider to perform the specific services contracted for, and only (a) if the service provider executes Putnam’s standard confidentiality agreement, or (b) pursuant to an agreement containing a confidentiality provision that has been approved by the Legal and Compliance Department. Examples of such service providers include proxy solicitors and proxy vote tabulators, mail services, and providers of other administrative services, and Information Services Division consultants who have access to non-public personal information.

COMMENTS

• Non-public personal information is any information that personally identifies a shareholder of a Putnam fund or client of a Putnam company and is not derived from publicly available sources. This privacy policy applies to shareholders or clients who are individuals, not institutions. However, as a general matter, all information that we receive about a shareholder of a Putnam fund or client of a Putnam company shall be treated as confidential. No employee may sell or otherwise provide shareholder or client lists or any other information relating to a shareholder or client to any marketing organization.

• All Putnam employees with access to shareholder or client account information must be trained in and follow Putnam’s security procedures designed to safeguard that information from unauthorized use. For example, a telephone representative must be trained in and follow Putnam’s security procedures to verify the identity of a caller requesting account information.

• Any questions regarding this privacy policy should be directed to Putnam’s Legal and Compliance Department. A violation of this policy will be subject to the sanctions imposed for violations of Putnam’s Code of Ethics.

• Employees must report any violation of this policy or any possible breach of the confidentiality of client information, whether intentional or accidental, to the managing director in charge of the employee’s business unit. Managing directors who are notified of such a violation or possible breach must immediately report it in writing to Putnam’s Chief Compliance Officer and, in the event of a breach of computerized data, Putnam’s Chief Technology Officer.

Rule 17: Anti-money Laundering Policy

No employee may engage in any money laundering activity or facilitate any money laundering activity through the use of any Putnam account or client account. Any situations giving rise to a suspicion that attempted money laundering may be occurring in any account must be reported immediately to the managing director in charge of the employee’s business unit. Managing directors who are notified of such a suspicion of money laundering activity must immediately report it in writing to Putnam’s Chief Compliance Officer and Chief Financial Officer.

Rule 18: Record Retention

All employees must comply with the record retention requirements applicable to the business unit. Employees should check with their managers or the Chief Administrative Officer of their division to determine what record retention requirements apply to their business unit.

The Code of Ethics incorporates any relevant requirements of the U.K. regulator, and the Financial Services Authority (FSA), and will be amended from time to time to reflect any U.K. regulatory changes as required.

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SECTION IV -- Special Rules for Officers and Employees of Putnam Investments Limited (PIL)

Rule 1

In situations subject to Section I.A., Rule 1 (Restricted List Personal Securities Transactions), Putnam Investments Limited (PIL) employees must obtain clearance via the PTA online system.

EXCEPTION

Government securities and other related bonds issued by member countries of the Organization for Economic Co-Operation and Development are not subject to pre-clearance rules.

IMPLEMENTATION

The position of the London Code of Ethics Administrator is held by the PIL Compliance Officer. All requests for clearances must be made through the PTA online system. Pre-clearance for trades of fixed-income securities must be made by calling the Boston Administrator.

Putnam’s Code of Ethics Administrator in Boston (the Boston Administrator) has also been designated the Deputy London Administrator of PIL and has been delegated the right to approve or disapprove personal securities transactions in accordance with the requirements of Section I.A. Therefore, approval from the Code of Ethics Administrator for PIL employees to make personal securities investments constitutes approval under the Code of Ethics.

Both the Boston and London Administrators may record clearances in PTA for inspection by senior management and regulators.

Rule 2

No PIL employee may trade with any broker-dealer unless that broker-dealer has sent a letter to the PIL Compliance Officer agreeing to deliver copies of trade confirmations and statements to PIL. No PIL employee may enter into any margin or any other special dealing arrangement with any broker-dealer without the prior written consent of the PIL Compliance Officer.

IMPLEMENTATION

PIL employees will be notified separately of this requirement once a year by the PIL Compliance Officer, and are required to provide an annual certification of compliance with the Rule.

All PIL employees must inform the PIL Compliance Officer of the names of all brokers-dealers with whom they trade prior to trading. The PIL Compliance Officer will send a letter to the broker(s) in question requesting them to agree to deliver copies of confirms to PIL. PIL employees may trade with a broker only when the PIL Compliance Officer has received the signed agreement from that broker.

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Rule 3

For purposes of the Code of Ethics, including Putnam’s Policy Statement on Insider Trading Prohibitions, PIL employees must also comply with Part V of the Criminal Justice Act 1993 on insider dealing.

IMPLEMENTATION

To ensure compliance with U.K. insider dealing legislation, PIL employees must observe the relevant procedures set forth in PIL’s Compliance Manual, a copy of which is sent to each PIL employee, and must sign an annual certification as to compliance.

Rule 4: Inducement Policy for All PIL Employees

See Appendix F: Inducement Policy for PIL Employees, and Appendix G: Record of Inducement for PIL Employees.

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SECTION V -- Reporting Requirements

Reporting of Personal Securities Transactions

Rule 1: Broker Confirmations and Statements

Each Putnam employee shall ensure that copies of all confirmations for securities transactions for personal brokerage accounts, and brokerage account statements are sent to the Putnam Compliance Department Code of Ethics Administrator. (For the purpose of this Rule, securities shall also include ETFs, futures, and other derivatives on broad-based market indexes excluded from the pre-clearance requirement.) Statements and confirmations are required for Putnam funds not held at Putnam or in a Putnam retirement plan, as well as for U.S. mutual funds sub-advised by Putnam.

IMPLEMENTATION

A. Putnam employees should contact the Code of Ethics Administrator for a 407 letter instructing the broker to mail copies of confirmations and statements to Putnam. It is the employees’ responsibility to follow up with the broker on a reasonable basis to ensure that instructions are being followed.

B. Upon hire, Putnam employees are required to establish their broker profiles in PTA.

C. Specific procedures apply to employees of PIL. Employees of PIL should contact the London Code of Ethics Administrator.

D. Failure of a broker-dealer to comply with the instructions of a Putnam employee to send confirmations shall be a violation by the Putnam employee of this Rule. Similarly, failure by an employee to report the existence of a personal account and, if the account is opened after joining Putnam, failure to obtain proper authorization to establish the account shall be a violation of this Rule.

E. Statements and confirmations must also be sent for members of an employee’s immediate family, including statements from a family member’s 401(k)/Profit Sharing Plan at another employer.

F. Employees are not required to provide broker confirmations and statements for MMC transactions in Putnam’s 401(k)/Profit Sharing and Stock Purchase Plan accounts.

COMMENTS

• Transactions for personal accounts is defined broadly to include more than transactions in accounts under an employee’s own name. (See Definitions.)

• Statements and confirmations are required for all personal securities transactions, whether or not exempted or excepted by this Code.

• To the extent that a Putnam employee has investment authority over securities transactions of a family trust or estate, confirmations of those transactions must also be made, unless the employee has received a prior written exception from the Code of Ethics Officer.

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Rule 2: Access Person – Quarterly Transaction Report

Every Access Person shall file a quarterly report within fifteen calendar days of the end of each quarter, recording all purchases and sales of securities for personal accounts as defined in the Definitions section. (For the purpose of this Rule, “securities” shall include exchange-traded funds (ETFs), futures, and any option on a security or securities index, including broad-based market indexes excluded from the pre-clearance requirement, and shall also include transactions in Putnam open-end funds if the account for the Putnam funds is not held at Putnam or in a Putnam retirement plan and for transactions in U.S. mutual funds sub-advised by Putnam.)

IMPLEMENTATION

It is mandatory that all Access Persons file a quarterly transaction report in the PTA online system. The form shall contain a representation that employees have complied fully with all provisions of the Code of Ethics.

The date for each transaction required to be disclosed in the quarterly report is the trade date for the transaction, not the settlement date.

Planned absences, i.e., vacations, leaves (other than certain medical leaves), or business trips, are not valid excuses for providing late reports. Failure to meet the deadline violates the Code’s rules and sanctions may be imposed.

COMMENT

If the requirement to file a quarterly report applies to you and you fail to report within the required 15-day period, monetary fines or harsher sanctions will be imposed. It is the responsibility of the employee to request an early report if he has knowledge of a planned absence, i.e., vacation, business trip, or leave.

Rule 3: Access Person - Initial/Annual Holdings Report

Access Persons must disclose their personal securities holdings in the Code of Ethics monitoring system, PTA, upon commencement of employment (within ten days of hire) and thereafter on an annual basis. These SEC requirements are mandatory and designed to facilitate the monitoring of personal securities transactions. Putnam’s Code of Ethics Administrator provides Access Persons with instructions regarding their submissions and certifications of these reports in PTA.

Non-Access Persons must disclose their brokerage accounts upon 30 days of hire.

Rule 4: Certifications

All employees are required to submit a certification in PTA annually attesting to compliance with all of the conditions of the Code of Ethics.

Rule 5: Roles at Other Entities

Upon approval of an outside business affiliation by the Code of Ethics Officer, employees must complete the Outside Business Affiliation profile in the Disclosure section of PTA.

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Rule 6: Reporting of Irregular Activity

If a Putnam employee suspects that fraudulent, illegal, or other irregular activity (including violations of the Code of Ethics) might be occurring at Putnam, the activity should be reported immediately to the managing director in charge of that employee’s business unit. Managing directors who are notified of any such activity must immediately report it in writing to Putnam’s Chief Financial Officer and Putnam’s Chief Compliance Officer.

An employee who does not feel comfortable reporting this activity to the managing director may instead contact the Chief Compliance Officer, the Putnam or MMC Ethics hotlines, or the Ombudsman.

Contact information for these hotlines is located on the PTA home page and on the Chief Compliance Officer’s intranet site.

Rule 7: Ombudsman

Putnam has established the office of the corporate ombudsman as a resource to help employees address legal or ethical issues in the workplace and to allow employees to voice concerns or seek clarity on issues. The Ombudsman provides a confidential, independent, and impartial source to employees to discuss potential violations of law or of company standards without fear of retribution, and serves as a neutral party with no vested interest in a particular outcome. The Ombudsman is available on an anonymous basis by calling 1-866-ombuds7 (866-662-8377) or by calling 1-617-760-8246.

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SECTION VI -- Education Requirements

Every Putnam employee has an obligation to fully understand the rules and requirements of the Code of Ethics.

Rule 1: Distribution of Code

A copy of the Code of Ethics will be distributed to every Putnam employee at least annually. All Access Persons will be required to certify annually that they have read, understood, and will comply with the provisions of the Code of Ethics, including the Code’s Policy Statement Concerning Insider Trading Prohibitions.

Rule 2: Annual Training Requirement

Every employee will be required to complete training on Putnam’s Code of Ethics on an annual basis.

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SECTION VII -- Compliance and Appeal Procedures

A. Restricted List

The Code of Ethics Administrator will maintain the Restricted List. No employee may engage in a personal securities transaction without prior clearance on any day, even if the employee believes that the trade will be subject to an exception.

B. Consultation of Restricted List

It is the responsibility of each employee to pre-clear through the pre-clearance system, or consult with the Code of Ethics Administrator, prior to engaging in a personal securities transaction, to determine if the security he proposes to trade is on the Restricted List and, if so, whether it is subject to the large-cap exception. The pre-clearance system and the Code of Ethics Administrator will be able to tell the employee whether a security is on the Restricted List. No other information about the Restricted List is available through the pre-clearance system.

C. Request for Determination

An employee who has a question concerning the applicability of the Code of Ethics to a particular situation shall request a determination from the Code of Ethics Officer before engaging in the conduct or personal securities transaction about which he has a question.

If the question pertains to a personal securities transaction, the request shall state for whose account the transaction is proposed, the relationship of that account to the employee, the security proposed to be traded, the proposed price and quantity, the entity with whom the transaction will take place (if known), and any other information or circumstances of the trade that could have a bearing on the Code of Ethics Officer’s determination. If the question pertains to other conduct, the request for determination shall give sufficient information about the proposed conduct to assist the Code of Ethics Officer in ascertaining the applicability of the Code. In every instance, the Code of Ethics Officer may request additional information, and may decline to render a determination if the information provided is insufficient.

The Code of Ethics Officer shall make every effort to render a determination promptly.

No perceived ambiguity in the Code of Ethics shall excuse any violation. Any person who believes the Code to be ambiguous in a particular situation should request a determination from the Code of Ethics Officer.

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D. Request for Ad Hoc Exemption

Any employee who wishes to obtain an ad hoc exemption under Section I.D., Rule 2, should request from the Code of Ethics Officer an exemption in writing in advance of the conduct or transaction sought to be exempted. In the case of a personal securities transaction, the request for an ad hoc exemption shall give the same information about the transaction required in a request for determination under Section VII.C., and should state why the proposed personal securities transaction would be unlikely to affect a highly institutional market, or is unrelated economically to securities to be purchased, sold, or held by any Putnam client. In the case of other conduct, the request shall give information sufficient for the Code of Ethics Officer to ascertain whether the conduct raises questions of propriety or conflict of interest, real or apparent.

The Code of Ethics Officer shall make reasonable efforts to promptly render a written determination concerning the request for an ad hoc exemption.

E. Appeal to Code of Ethics Officer with Respect to Restricted List

If an employee ascertains that a security that he wishes to trade for his personal account appears on the Restricted List, and thus the transaction is prohibited, he may appeal the prohibition to the Code of Ethics Officer by submitting a written memorandum containing the same information as would be required in a request for a determination. The Code of Ethics Officer shall make every effort to respond to the appeal promptly.

F. Information Concerning Identity of Compliance Personnel

The names of Code of Ethics personnel are available by contacting the Legal and Compliance Department and will be published on Putnam’s intranet site.

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SECTION VIII -- Sanctions

Sanction Guidelines

The Code of Ethics Oversight Committee is responsible for setting sanctions policies for violating the Code. The Committee has adopted the following minimum monetary sanctions for violations of the Code. These sanctions apply even if the exception results from inadvertence rather than intentional misbehavior. The Code of Ethics Officer is authorized to impose the minimum sanction on employees without further Committee action. However, the sanctions noted below are only minimums and the Committee reserves the right to impose additional sanctions such as higher monetary sanctions, trading bans, suspension, or termination of employment as it determines to be appropriate.

A. The minimum sanction for a violation of the following Rules is disgorgement of any profits or payment of avoided losses and the following payments:

Section I.A., Rule 1 (Pre-clearance and Restricted List)Section I.B., Rule 1 (Short selling)Section I.B., Rule 2 (IPOs)Section I.B., Rule 3 (Private Placements)Section I.B., Rule 4 (Trading with Inside Information)Section I.B., Rules 6-8 (Holding and Trading of Putnam Funds)Section II, Rule 2 (7-Day Rule)Section II, Rule 3 (Blackout Rule)Section II, Rule 4 (Contra-Trading Rule)Section II, Rule 5 (Trading for Personal Benefit)

Officer Level	SMD/MD	SVP/VP	AVP/non-officer
1st violation	$ 500	$250	$ 50
2nd	$1,000	$500	$100
3rd	Minimum monetary sanction as above with ban on all new personal
	individual investments.

B. The minimum sanction for violations of all other Rules in the Code is as follows:

Officer Level	SMD/MD	SVP/VP	AVP/non-officer
1st violation	$100	$ 50	$25
Subsequent	$200	$100	$50

The reference period for determining whether a violation is initial or subsequent will be five years.

NOTE

The Committee’s belief that an employee has violated the Code of Ethics intentionally will result in more severe sanctions than outlined in the guidelines above. The Code of Ethics Oversight Committee retains the right to increase or decrease the sanctions for a particular violation in light of the circumstances.

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APPENDIX A: Insider Trading Prohibitions Policy Statement

Putnam has always forbidden trading by its employees on material non-public information (inside information). Tough federal laws make it important for Putnam to state that prohibition in the strongest possible terms, and to establish, maintain, and enforce written policies and procedures to prevent the use of material non-public information.

Unlawful trading while in possession of inside information can be a crime. Federal law provides that an individual convicted of trading on inside information may go to jail for a period of time. There is also significant monetary liability for an inside trader; the Securities and Exchange Commission can seek a court order requiring a violator to pay back profits, as well as penalties substantially greater than those profits. In addition private plaintiffs can seek recovery for harm suffered by them. The inside trader is not the only subject to liability. In certain cases, controlling persons of inside traders, including supervisors of inside traders or Putnam itself, can be liable for large penalties.

Section A. of this Policy Statement contains rules concerning inside information. Section B. contains a discussion of what constitutes unlawful insider trading.

Neither material, non-public information nor unlawful insider trading is easy to define. Section B. of this Policy Statement gives a general overview of the law in this area. However, the legal issues are complex and must be resolved by the Code of Ethics Officer. If an employee has any doubt as to whether she has received material, non-public information, she must consult with the Code of Ethics Officer prior to using that information in connection with the purchase or sale of a security for his own account or the account of any Putnam client, or communicating the information to others. A simple rule of thumb is if you think the information is not available to the public at large, don’t disclose it to others and don’t trade securities to which the inside information relates.

An employee aware of, or in possession of, inside information must report it immediately to the Code of Ethics Officer. If an employee has failed to consult the Code of Ethics Officer, Putnam will not excuse employee misuse of inside information on the grounds that the employee claims to have been confused about this Policy Statement or the nature of the information in his possession.

If Putnam determines, in its sole discretion, that an employee has failed to abide by this Policy Statement, or has engaged in conduct that raises a significant question concerning insider trading, he will be subject to disciplinary action, including termination of employment.

There are no exceptions to this policy statement and no one is exempt.

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APPENDIX A: DEFINITIONS: Insider Trading

Code of Ethics Administrator

The individual designated by the Code of Ethics Officer to assume responsibility for day-to-day, non-discretionary administration of this Policy Statement. The Code of Ethics Administrator is Laura Rose.

Code of Ethics Officer

The Putnam officer who has been assigned the responsibility of enforcing and interpreting this Code. The Code of Ethics Officer shall be the Chief Compliance Officer or such other person as is designated by the Chief Executive Officer of Putnam Investments. If the Code of Ethics Officer is unavailable, the Deputy Code of Ethics Officer shall act in his stead. The Code of Ethics Officer is Tony Ruys de Perez. The Deputy Code of Ethics Officer is Kathleen Griffin.

Immediate family Spouse, partner, minor children, or other relatives living in the same household as the Putnam employee.

Purchase or sale of a security Any acquisition or transfer of any interest in the security for direct or indirect consideration, including the writing of an option.

Putnam Any or all of Putnam Investments Trust, and its subsidiaries, any one of which shall be a Putnam company.

Putnam client Any client of the Putnam mutual funds, or any advisory, trust, or other client for whom Putnam manages money.

Putnam employee (or employee) Any employee of Putnam.

Security Anything defined as a security under federal law. The term includes any type of equity or debt security, any interest in a business trust or partnership, and any rights relating to a security, such as put and call options, warrants, convertible securities, and securities indexes. (Note: The definition of security in this Insider Trading Prohibitions Policy Statement varies significantly from that in the Code of Ethics. For example, the definition in this Policy Statement specifically includes all securities of any type.)

Transaction for a personal account (or personal securities transaction)

Securities transactions: (a) for the personal account of any employee; (b) for the account of a member of the immediate family of any employee; (c) for the account of a partnership in which a Putnam employee or immediate family member is a partner with investment discretion; (d) for the account of a trust in which a Putnam employee or immediate family member is a trustee with investment discretion; (e) for the account of a closely held corporation in which a Putnam employee or immediate family member holds shares and for which he has investment discretion; and (f ) for any account other than a Putnam client account that receives investment advice of any sort from the employee or immediate family member, or as to which the employee or immediate family member has investment discretion. Officers and employees of PIL must also consult the relevant procedures on compliance with U.K. insider dealing legislation set forth in PIL’s Compliance Manual (See Rule 3 of Section IV of the Code of Ethics).

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APPENDIX A -- SECTION I: Rules Concerning Inside Information

Rule 1: Inside Information

No Putnam employee shall purchase or sell any security listed on the Inside Information List (the Red List) either for his personal account or for a Putnam client.

IMPLEMENTATION

When an employee contacts the Code of Ethics Administrator seeking clearance for a personal securities transaction, the Code of Ethics Administrator’s response as to whether a security appears on the Restricted List will include securities on the Red List.

COMMENT

This Rule is designed to prohibit any employee from trading a security while Putnam may have inside information concerning that security or the issuer. Every trade, whether for a personal account or for a Putnam client, is subject to this rule.

Rule 2: Material Non-public Information

No Putnam employee shall purchase or sell any security, either for a personal account or for the account of a Putnam client, while in possession of material, non-public information concerning that security or the issuer, without the prior written approval of the Code of Ethics Officer.

IMPLEMENTATION

In order to obtain prior written approval of the Code of Ethics Officer, a Putnam employee should follow the reporting steps prescribed in Rule 3.

COMMENTS

• Rule 1 concerns the conduct of an employee when Putnam possesses material, non-public information. Rule 2 concerns the conduct of an employee who herself possesses material, non-public information about a security that is not yet on the Red List.

• If an employee has any question as to whether information she possesses is material and/or non-public information, she must contact the Code of Ethics Officer immediately in accordance with Rule 3 prior to purchasing or selling any security related to the information or communicating the information to others. The Code of Ethics Officer shall have the sole authority to determine what constitutes material, non-public information for the purposes of this Policy Statement.

Rule 3: Reporting of Material Non-public Information

Any Putnam employee who believes he is aware of or has received material, non-public information concerning a security or an issuer shall immediately report the information to the Code of Ethics Officer, the Deputy Code of Ethics Officer, or in their absence, a lawyer in the Putnam Legal and Compliance Department and to no one else. After reporting the information, the Putnam employee shall comply strictly with Rule 2 by not trading in the security without the prior written approval of the Code of Ethics Officer and shall (a) take precautions to ensure the continued confidentiality of the information and (b) refrain from communicating the information in question to any person.

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IMPLEMENTATION

A. In order to make any use of potential material non-public information, including purchasing or selling a security or communicating the information to others, an employee must communicate that information to the Code of Ethics Officer in a way designed to prevent the spread of such information. Once the employee has reported potential material non-public information to the Code of Ethics Officer, the Code of Ethics Officer will evaluate whether information constitutes material non-public information, and whether a duty exists that makes use of such information improper. If the Code of Ethics Officer determines either (a) that the information is not material or is public, or (b) that use of the information is proper, he will issue a written approval to the employee specifically authorizing trading while in possession of the information, if the employee so requests. If the Code of Ethics Officer determines (a) that the information may be nonpublic and material, and (b) that use of such information may be improper, he will place the security that is the subject of such information on the Red List.

B. An employee who reports potential inside information to the Code of Ethics Officer should expect that the Code of Ethics Officer will need significant information, and time to gather such information, to make the evaluation, including information about (a) the manner in which the employee acquired the information, and (b) the identity of individuals to whom the employee has revealed the information, or who have otherwise learned the information. In appropriate situations, the Code of Ethics Officer will normally place the affected security or securities on the Red List pending the completion of his evaluation.

C. If an employee possesses documents, disks, or other materials containing the potential inside information, an employee must take precautions to ensure the confidentiality of the information in question. Those precautions include (a) putting documents containing such information out of the view of a casual observer, and (b) securing files containing such documents or ensuring that computer files reflecting such information are secure from viewing by others.

D. Members of the executive board of directors and members of the Chief Financial Officer’s staff may not trade securities of MMC in the period from the end of each calendar quarter to the date of announcement of MMC’s earnings for such quarter.

COMMENT

While all employees must pre-clear trades of MMC securities and make sure they are not in possession of material inside information about MMC when trading, certain employees who may receive information about Putnam’s earnings are subject to the rules above concerning trading blackout periods.

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APPENDIX A -- SECTION II: Overview of Insider Trading

Introduction

This section of the Policy Statement provides guidelines for employees as to what may constitute inside information. It is possible that in the course of her employment, an employee may receive inside information. No employee should misuse that information, either by trading for her own account or by communicating the information to others.

What constitutes unlawful insider trading?

The basic definition of unlawful insider trading is trading on material non-public information (also called inside information) by an individual who has a duty not to take advantage of the information. The following sections help explain the definition.

What is material information?

Trading on inside information is not a basis for liability unless the information is material. Information is material if a reasonable person would attach importance to the information in determining his course of action with respect to a security. Information that is reasonably likely to affect the price of a company’s securities is material, but effect on price is not the sole criterion for determining materiality. Information that employees should consider material includes, but is not limited to, dividend changes, earnings estimates, changes in previously released earnings estimates, reorganization, recapitalization, asset sales, plans to commence a tender offer, merger or acquisition proposals or agreements, major litigation, liquidity problems, significant contracts, and extraordinary management developments.

Material information does not have to relate to a company’s business. For example, a court considered as material certain information about the contents of a forthcoming newspaper column that was expected to affect the market price of a security. In that case, a reporter for the Wall Street Journal was found criminally liable for disclosing to others the dates that reports on various companies would appear in the Journal’s “Heard on the Street” column and whether those reports would be favorable or not.

What is non-public information?

Information is non-public until it has been effectively communicated to, and sufficient opportunity has existed for it to be absorbed by, the marketplace. One must be able to point to some fact to show that the information is generally public. For example, information found in a report filed with the Securities and Exchange Commission, or appearing in Dow Jones, Reuters, the Wall Street Journal, or other publications of general circulation would be considered public.

Who has a duty not to “take advantage” of inside information?

Unlawful insider trading occurs only if there is a duty not to take advantage of material non-public information. When there is no such duty, it is permissible to trade while in possession of such information. Questions as to whether a duty exists are complex, fact specific, and must be answered by a lawyer. If you have any doubt, err on the side of caution.

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Insiders and Temporary Insiders Corporate insiders have a duty not to take advantage of inside information. The concept of insider is broad. It includes officers, directors, and employees of a corporation. In addition, a person can be a temporary insider if she enters into a special confidential relationship with a corporation and, as a result, is given access to information concerning the corporation’s affairs. A temporary insider can include, among others, accounting firms, consulting firms, law firms, banks, and the employees of such organizations. Putnam would generally be a temporary insider of a corporation it advises or for which it performs other services, because typically Putnam clients expect Putnam to keep any information disclosed to it confidential.

EXAMPLE

An investment advisor to the pension fund of a large publicly traded corporation, Acme, Inc., learns from an Acme employee that Acme will not be making the minimum required annual contribution to the pension fund because of a serious downturn in Acme’s financial situation. The information conveyed is material and non-public.

COMMENT

Neither the investment advisor, its employees, nor its clients can trade on the basis of that information, because the investment advisor and its employees could be considered temporary insiders of Acme.

Misappropriators Certain people who are not insiders (or temporary insiders) also have a duty not to deceptively take advantage of inside information. Included in this category is an individual who misappropriates (or takes for his own use) material non-public information in violation of a duty owed either to the corporation that is the subject of inside information or some other entity. Such a misappropriator can be held liable if he trades while in possession of that material non-public information.

EXAMPLE

The Chief Investment Officer of Acme, Inc., is aware of Acme’s plans to engage in a hostile takeover of Profit, Inc. The proposed hostile takeover is material and non-public.

COMMENT

The Chief Investment Officer of Acme cannot trade in Profit, Inc.’s stock for his own account. Even though he owes no duty to Profit, Inc., or its shareholders, he owes a duty to Acme not to take advantage of the information about the proposed hostile takeover by using it for his personal benefit.

Tippers and Tippees A person (the tippee) who receives material non-public information from an insider or misappropriator (the tipper) has a duty not to trade while in possession of that information if he knew, or should have known, that the information was provided by the tipper for an improper purpose and in breach of a duty owed by the tipper. In this context, it is an improper purpose for a person to provide such information for personal benefit.

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EXAMPLE

The Chief Executive Officer of Acme, Inc., tells his daughter that negotiations concerning a previously announced acquisition of Acme have been terminated. This news is material and, at the time the father tells his daughter, non-public. The daughter sells her shares of Acme.

COMMENT

The father is a tipper because he has a duty to Acme and its shareholders not to take advantage of the information concerning the breakdown of negotiations, and he has conveyed the information for an improper purpose. The daughter is a tippee and is liable for trading on inside information because she knew, or should have known, that her father was conveying the information to her for his personal benefit, and that her father had a duty not to take advantage of Acme information.

A person can be a tippee even if he did not learn the information directly from the tipper, but learned it from a previous tippee.

EXAMPLE

An employee of a law firm that works on mergers and acquisitions learns at work about impending acquisitions. She tells her friend and her friend’s stockbroker about the upcoming acquisitions on a regular basis. The stockbroker tells the brother of a client on a regular basis, who in turn tells two friends, A and B. A and B buy shares of the companies being acquired before the public announcement of the acquisition, and regularly profit from such purchases. A and B do not know the employee of the law firm. They do not, however, ask about the source of the information.

COMMENT

A and B, although they have never heard of the tipper, are tippees because they did not ask about the source of the information, even though they were experienced investors, and were aware that the “tips” they received from this particular source were accurate.

Who can be liable for insider trading?

The categories of individuals discussed above (insiders, temporary insiders, misappropriators, or tippees) can be liable if they trade while in possession of material non-public information.

In addition, individuals other than those who actually trade on inside information can be liable for trades of others. A tipper can be liable if (a) he provided the information in exchange for a personal benefit in breach of a duty, and (b) the recipient of the information (the tippee) traded while in possession of the information.

Most importantly, a controlling person can be liable if the controlling person knew or recklessly disregarded the fact that the controlled person was likely to engage in misuse of inside information and failed to take appropriate steps to prevent it. Putnam is a controlling person of its employees. In addition, certain supervisors may be controlling persons of those employees they supervise.

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EXAMPLE

A supervisor of an analyst learns that the analyst has, over a long period of time, secretly received material inside information from Acme, Inc.’s Chief Investment Officer. The supervisor learns that the analyst has engaged in a number of trades for his personal account on the basis of the inside information. The supervisor takes no action.

COMMENT

Even if he is not liable to a private plaintiff, the supervisor can be liable to the Securities and Exchange Commission for a civil penalty of up to three times the amount of the analyst’s profit.

Penalties for insider trading

Penalties for misuse of inside information are severe, both for individuals involved in such unlawful conduct and their employers. A person who violates the insider trading laws can be subject to some or all of the types of penalties below, even if he does not personally benefit from the violation. Penalties include:

• Jail sentences, criminal monetary penalties

• Injunctions permanently preventing an individual from working in the securities industry

• Injunctions ordering an individual to disgorge profits obtained from unlawful insider trading

• Civil penalties substantially greater than the profit gained or loss avoided by the trader, even if the individual paying the penalty did not trade or did not benefit personally

• Civil penalties for the employer or other controlling person

• Damages in the amount of actual losses suffered by other participants in the market for the security at issue

Regardless of whether penalties or money damages are sought by others, Putnam will take whatever action it deems appropriate, including dismissal, if Putnam determines, in its sole discretion, that an employee appears to have committed any violation of this Policy Statement, or to have engaged in any conduct which raises significant questions about whether an insider trading violation has occurred.

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APPENDIX B: Policy Statement Regarding Employee Trades in Shares of Putnam Closed-End Funds

Pre-clearance

Any purchase or sale of Putnam closed-end fund shares by a Putnam employee must be pre-cleared with the Code of Ethics Administrator. A list of the closed-end funds can be obtained from the Code of Ethics Administrator. The PTA system is not available for Putnam closed-end fund clearance.

Reporting

As with any purchase or sale of a security, duplicate confirmations of all such purchases and sales must be forwarded to the Code of Ethics Officer by the broker-dealer utilized by an employee. If you are required to file a quarterly report of all personal securities transactions, this report should include all purchases and sales of closed-end fund shares.

Special Rules Applicable to Managing Directors of Putnam Investment Management, LLC and officers of the Putnam Funds.

Please be aware that managing directors of Putnam Investment Management, Inc., the investment manager of the Putnam mutual funds, and officers of the Putnam Funds will not receive clearance to engage in any combination of purchase and sale, or sale and purchase, of the shares of a given closed-end fund within six months of each other. Therefore, purchases should be made only if you intend to hold the shares more than six months; no sales of fund shares should be made if you intend to purchase additional shares of that same fund within six months.

You are also required to file certain forms with the Securities and Exchange Commission in connection with purchases and sales of Putnam closed-end funds. Please contact the Code of Ethics Officer Administrator for further information. Please contact the Code of Ethics Officer or Deputy Code of Ethics Officer if there are any questions regarding these matters.

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APPENDIX C: Contra-Trading Rule Clearance Form

To: Code of Ethics Officer

From: _____________________________________________ ____________________________

Date:  __________________________________________ _______________________________

Re: Personal Securities Transaction of_________________ ______________________________

This serves as prior written approval of the personal securities transaction described below:

Name of portfolio manager contemplating personal trade: ________________________________

Security to be traded: ___________________________ _________________________________

Amount to be traded:

_____________________________________________________________________

Fund holding securities:

____________________________________________________________________

Amount held by fund:

_____________________________________________________________________

Reason for personal trade:

__________________________________________________________________

Specific reason sale of securities is inappropriate for fund: ________________________________

__________________________________________________________________________________

__________________________________________________________________________________

__________

(Please attach additional sheets if necessary.)

CIO approval:                        ____________________ Date:

Legal/compliance approval:    ____________________ Date:

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APPENDIX D: CFA Institute Code of Ethics and Standards of Professional Conduct

The CFA Institute Code of Ethics and Standards of Professional Conduct (Code and Standards) are fundamental to CFA Institute’s values and essential to achieving its mission to lead the investment profession globally by setting high standards of education, integrity, and professional excellence. High ethical standards are critical to maintaining the public’s trust in financial markets and in the investment profession.

Since their creation in the 1960s, the Code and Standards have promoted the integrity of CFA Institute members and served as a model for measuring the ethics of investment professionals globally, regardless of job function, cultural differences, or local laws and regulations. All CFA Institute members (including holders of the Chartered Financial Analyst® (CFA®) designation) and CFA candidates must abide by the Code and Standards and are encouraged to notify their employer of this responsibility. Violations may result in disciplinary sanctions by CFA Institute. Sanctions can include revocation of membership, candidacy in the CFA Program, and the right to use the CFA designation.

The Code of Ethics

Members of CFA Institute (including Chartered Financial Analyst® (CFA®) charterholders) and candidates for the CFA designation (“Members and Candidates”) must:

• Act with integrity, competence, diligence, and respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets.

• Place the integrity of the investment profession and the interests of clients above their own personal interests.

• Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities.

• Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession.

• Promote the integrity of, and uphold the rules governing, capital markets.

• Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals.

Standards of Professional Conduct

I. PROFESSIONALISM

A. Knowledge of the Law. Members and Candidates must understand and comply with all applicable laws, rules, and regulations (including the CFA Institute Code of Ethics and Standards of Professional Conduct) of any government, regulatory organization, licensing agency, or professional association governing their professional activities. In the event of conflict, Members and Candidates must comply with the more strict law, rule, or regulation. Members and Candidates must not knowingly participate or assist in and must dissociate from any violation of such laws, rules, or regulations.

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B. Independence and Objectivity. Members and Candidates must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities. Members and Candidates must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity.

C. Misrepresentation. Members and Candidates must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

D. Misconduct. Members and Candidates must not engage in any professional conduct involving dishonesty, fraud, or deceit, or commit any act that reflects adversely on their professional reputation, integrity, or competence.

II. INTEGRITY OF CAPITAL MARKETS

A. Material Non-public Information. Members and Candidates who possess material, non-public information that could affect the value of an investment must not act or cause others to act on the information.

B. Market Manipulation. Members and Candidates must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

III.DUTIES TO CLIENTS

A. Loyalty, Prudence, and Care. Members and Candidates have a duty of loyalty to their clients and must act with reasonable care and exercise prudent judgment. Members and Candidates must act for the benefit of their clients and place their clients’ interests before their employer’s or their own interests. In relationships with clients, Members and Candidates must determine applicable fiduciary duty and must comply with such duty to persons and interests to whom it is owed.

B. Fair Dealing. Members and Candidates must deal fairly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

C. Suitability.

1. When Members and Candidates are in an advisory relationship with a client, they must:

a. Make a reasonable inquiry into a client’s or prospective clients’ investment experience, risk and return objectives, and financial constraints prior to making any investment recommendation or taking investment action and must reassess and update this information regularly.

b. Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates, and constraints before making an investment recommendation or taking investment action.

c. Judge the suitability of investments in the context of the client’s total portfolio.

2. When Members and Candidates are responsible for managing a portfolio to a specific mandate, strategy, or style, they must only make investment recommendations or take investment actions that are consistent with the stated objectives and constraints of the portfolio.

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D. Performance Presentation. When communicating investment performance information, Members or Candidates must make reasonable efforts to ensure that it is fair, accurate, and complete.

E. Preservation of Confidentiality. Members and Candidates must keep information about current, former, and prospective clients confidential unless:

1. The information concerns illegal activities on the part of the client or prospective client.

2. Disclosure is required by law.

3. The client or prospective client permits disclosure of the information.

IV. DUTIES TO EMPLOYERS

A. Loyalty. In matters related to their employment, Members and Candidates must act for the benefit of their employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to their employer.

B. Additional Compensation Arrangements. Members and Candidates must not accept gifts, benefits, compensation, or consideration that competes with, or might reasonably be expected to create a conflict of interest with, their employer’s interest unless they obtain written consent from all parties involved.

C. Responsibilities of Supervisors. Members and Candidates must make reasonable efforts to detect and prevent violations of applicable laws, rules, regulations, and the Code and Standards by anyone subject to their supervision or authority.

V. INVESTMENT ANALYSIS, RECOMMENDATIONS, AND ACTION

A. Diligence and Reasonable Basis. Members and Candidates must:

1. Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations, and taking investment actions.

2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.

B. Communication with Clients and Prospective Clients. Members and Candidates must:

1. Disclose to clients and prospective clients the basic format and general principles of the investment processes used to analyze investments, select securities, and construct portfolios, and must promptly disclose any changes that might materially affect those processes.

2. Use reasonable judgment in identifying which factors are important to their investment analysis, recommendations, or actions and include those factors in communications with clients and prospective clients.

3. Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

C. Record Retention. Members and Candidates must develop and maintain appropriate records to support their investment analysis, recommendations, actions, and other investment-related communications with clients and prospective clients.

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VI. CONFLICTS OF INTEREST

A. Disclosure of Conflicts. Members and Candidates must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Members and Candidates must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

B. Priority of Transactions. Investment transactions for clients and employers must have priority over investment transactions in which a Member or Candidate is the beneficial owner.

C. Referral Fees. Members and Candidates must disclose to their employer, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received by, or paid to, others for the recommendation of products or services.

VII. RESPONSIBILITIES AS A CFA INSTITUTE MEMBER OR CFA CANDIDATE

A. Conduct as Members and Candidates in the CFA Program. Members and Candidates must not engage in any conduct that compromises the reputation or integrity of the CFA Institute or the CFA designation or the integrity, validity, or security of the CFA examinations.

B. Reference to the CFA Institute, the CFA designation, and the CFA Program. When referring to the CFA Institute, CFA Institute membership, the CFA designation, or candidacy in the CFA Program, Members and Candidates must not misrepresent or exaggerate the meaning or implications of membership in the CFA Institute, holding the CFA designation, or candidacy in the CFA Program.

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APPENDIX E: Report of Entertainment Form

This form must be filed with the Putnam’s Legal and Compliance Department and sanctions may apply if received after 10 business days of attending an event. Planned absences, i.e., vacations, leaves (other than certain medical leaves), or business trips are not valid excuses for providing late reports. Failure to meet the deadline violates the Code’s rules and sanctions may be imposed.

Send report to:
Jonathan Ramsey
Compliance Coordinator
COE Mailstop A-16

OR

Attach to an e-mail to:
Jonathan_Ramsey@putnam.com

Name of
employee:_______________________________________________________________________

Name of party providing entertainment:

Firm:

__________________________________________________________________________________

Person:

________________________________________________________________________________

Date of entertainment:

____________________________________________________________________

Describe entertainment provided:

___________________________________________________________
(e.g., name and location of restaurant, sporting, or cultural event)

Value of entertainment (excluding meals): ____________________________________________

Signature: ______________________________________________   Date:
___________________________

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APPENDIX F -- Inducement Policy for Putnam Investments Limited (PIL) Employees

Inducements

Putnam Investments Limited has adopted the following procedures to enable it to comply with, and demonstrate compliance with, the requirements in this area:

All gifts, business meals, entertainment, or other inducements received by any employee must be reported on the appropriate forms to the PIL Compliance Officer within ten days of receipt. PIL’s policy limits gifts or business meals to a value of £100 (150 euros or equivalent) and entertainment to a value of £150 (225 euros or equivalent). Gifts, business meals, and entertainment that exceed these limits should be politely declined, explaining that PIL’s internal policies will not permit a breach of these limits.

There may be rare occasions where you are unexpectedly offered a gift or business meal or are entertained where the value exceeds the limits and it would be very discourteous (to a prospect/client) to decline, or difficult to pay part of the bill yourself (such as in a members’ dining club). In these circumstances the gift should be handed in to the PIL Compliance Officer, who will arrange to give it to charity, or the entertainment reported immediately to the PIL Compliance Officer with an explanation of the circumstances.

The policy regarding gifts, business meals, entertainment, or other inducements for giving or receiving is as follows. Where the gift or business meal is below £100 (150 euros or equivalent) or the entertainment is below £150 (225 euros or equivalent) for any individual, no pre-clearance is necessary. Above these levels, pre-clearance is required from the PIL Compliance Officer. If in doubt as to whether limits might be exceeded, please err on the side of caution and seek pre-clearance.

Anything above £25 (40 euros or equivalent) should be reported on the appropriate forms to the PIL Compliance Officer within ten days, who will review these on a monthly basis.

Anything below £25 (40 euros or equivalent), e.g., dealer gifts, a casual drink, or a snack, etc., need not be reported.

Where a working lunch is provided as part of an Analyst’s Day or Management Day, report this event and note the value as £0. This ensures that there is no potential for conflicts of interest and avoids guestimates of the cost.

No more than six entertainment events per year and no more than two events may be accepted from a single source.

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The record will contain details of:

the individuals concerned (from both PIL and the other party);

the nature and circumstances of the inducement;

the date; and

the approximate cost, if offered by PIL, although if it’s an in-house lunch/dinner, a statement to that effect will suffice.

The frequency and nature of any gifts, business meals, entertainment, or other inducement given or received, together with the names of those individuals entertained, is monitored periodically by the PIL Compliance Officer, and that monitoring is evidenced.

Where any deadlines or limits are exceeded, these will be reported to the Code of Ethics Officer on a monthly basis and sanctions may apply.

A template on which to record details of inducements given can be obtained from the PIL Compliance Officer.

Employees are also required to make an annual declaration that either they have reported all inducements given and received, or that they have not given or received any inducements, during the course of the year.

Further detailed guidance on PIL’s Inducement Policy is available in the PIL Compliance Manual.

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APPENDIX G -- Record of Inducement for Putnam Investments Limited (PIL)Employees

Director/Employee:

___________________________________________________________________

Inducement Given/Received:

____________________________________________________________
(Indicate which it is):

Nature of Inducement Given/Received:

____________________________________________________

Date of Giving/Receipt:

_________________________________________________________________

Name of Other Party:

__________________________________________________________________

Name(s) of Personnel of Other Party Involved:

______________________________________________

Name(s) of Other Putnam Individuals Involved:

______________________________________________

Approximate Value of Inducement (if Known):

_______________________________________________

Signature of PIL Director/Employee

Giving/Receiving Inducement ________________________________________ Date:
_______________

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INDEX
407 Letter	iv, 28
7-Day Rule	v, 12-13
90-Day Short Term Rule	v, 12
A
Access Persons
definition	vii
reporting requirements for	29
reporting transactions/holdings	29
special rules for personal securities transactions	12-15
Ad hoc exemption	32
Affiliated entities	23
Analysts, special rules	12, 13, 15
Annual Holdings Report	29
Anti-money Laundering Policy	25
Anti-bribery/Kickback Policy	18
Appeals procedures	32-33
B
Blackout rule, trading by portfolio managers,
analysts, and CIOs	v, 13-14
Boycotts	16
anti-trust and other laws	16
Bribes	18
Broker accounts	iv, 28
Confirmations and statements	28
C
CFA Institute Code of Ethics	24, 45-48
Standards of Professional Conduct	45-48
Chief Investment Officer
special rules on trading	12-15
Closed-end funds	iv, 43
Code of Ethics Administrator	vii
Code of Ethics Officer	vii
Deputy Code of Ethics Officer	vii
Code of Ethics Oversight Committee	viii
Commodities	ix
Compliance and appeal procedures	32-33
Computer system policies	24
Confidentiality	iv, 20
Confirmations and broker statements	iv, 28
Conflicts of interest	iii, vi, 16
Considered List – Limited Sales Exemption	3
Contra-trading rule	v, 14
clearance form	44
Corporate/political contributions	19
Corporate purchase of goods and services	22
Currencies	ix
D
Director
prohibited to serve for another entity	20

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Discretionary accounts	3-4
Dividend reinvestment program	9, 11
E
Education requirements	31
Employees
general rules for	16-25
personal political contributions	19
personal securities rules for all	1-11
(see also Access Persons)
Entertainment policies	16-18
Report of Entertainment Form	49
Excessive trading (over 10 traders) prohibited	iv, 10
Exchange traded index funds (ETFs)	ix, 29
F
Family members accounts	8
Family Members’ Conflict Policy	22-23
Fiduciary	21
Fraudulent or irregular activities reporting	30
G
Gifts and Entertainment Policy	iii, 16-18, 49
Gifts donated as a security	4
Goods and services, purchasing	22
Good-until-canceled (GTC) orders	10
H
Holdings of securities
disclosure by Access Persons	29
I
Initial Holdings Report	29
Initial public offerings/IPOs	5
Inside information
material, non-public information	6, 37
reporting material, non-public information	37-38
rules concerning	37-38
Inside Information List (Red List)	37-38
Insider trading
definitions	36
explanations of	39-42
liability for	41-42
penalties for	42
policy statement	35
prohibitions	iii, 35
rules concerning	37-38
sanctions for	34, 42
Investment clubs	21
Involuntary transactions, exemptions	4, 11
Irregular activity reporting	30
K
Kickback Policy	18
L
Large Cap Exemption	3
Limit Orders	10
Linked accounts	8

54

Lobbying Policy	19-20
M
Market timing prohibition	8
Marsh & McLennan (MMC) securities	iv, 1-2
Material Information	6, 37, 39-42
N
Naked options	10
Negotiations prohibition	22
Non-public information	iii, 6, 37, 39-42
Non-Putnam affiliates (NPAs)	23
O
Officer, prohibited to serve for another entity	20
Ombudsman	30
Options
defined as securities	4, 36
naked	10
relationship to securities on Restricted or Red Lists	4
Outside business affiliations	20-21
P
Partner, prohibited to serve for another entity	20
Partnerships, covered in personal securities transactions	ix, 36
Personal securities transaction	ix, 36
Personal Trading Assistant (PTA) system	iv, viii, 26, 28-30, 43
Accessing	1, 2
Political activities, contributions, lobbying	19-20
Portfolio managers, special rules on trading	12-15
Portfolio trading	12-15, 22
Pre-clearance	iv, 1-4
sanctions for failure to pre-clear properly	34
Privacy policy	24-25
Private offerings and private placement pre-approval	6
Prohibited transactions	5-10
Putnam Investments Limited (PIL)
special rules	26-27
record of inducement	52
Putnam Mutual Funds restrictions	iv, 7-9
90-day Rule	iv, 8-9
One-year Rule	iv, 8
Q
Quarterly Report of Securities Transactions	v. 29
R
Records
accuracy records policy	22
retention policy	25
Red List	37, 38
Reporting requirements	v, 28-30
Restricted List	viii, 1-5, 26, 32-34, 37
Roles at other entities	20-21
S
Sanctions	34-42
Securities donated	4
Shares by subscription, pre-clearance	3
Short selling	iv
Special rules for Investment Professionals	v, 12-15

55

T
Tender offers	4
Trustee, prohibited to serve for another entity	20
Trusts	ix, 36
U
U.S. government obligations	ix
V
Violations reporting	30
W
Warrants	36

56

EX-99.CODE ETH

Amendments to Putnam Investments
Code of Ethics dated December, 2005

Effective June 16, 2006 the following amendment was made to the Putnam Investments Code of Ethics:

Section III - Rule 5: Political Activities, Contributions, Solicitations, and Lobbying Policy

Under Employee Contributions (item #1):
The office of the State Treasurer of Connecticut, Vermont, or West Virginia
(Note: The State of West Virginia was added to this policy).

Effective July 17, 2006 the following amendment was made to the Putnam Investments Code of Ethics:

Section III - Rule 3: Gifts and Entertainment Policy

3. Any employee attending any entertainment event under the provision in sections (B)(1) or (B)(2) above must file a Report of Entertainment Form (attached as Appendix E) with the Code of Ethics Officer within 20 business days following the date of the entertainment event. Failure to file the notice is a violation of the Code of Ethics.

Appendix E

PUTNAM INVESTMENTS CODE OF ETHICS
REPORT OF ENTERTAINMENT

This form must be filed with the Putnam Legal and Compliance Department within
20 business days of date of entertainment.

Please e-mail to Putnam_Code_of_Ethics@putnam.com
Or return to Legal and Compliance Department, Mailstop A-16

Name of Employee: 

Name of Party Providing Entertainment – firm and person: 

Date of Entertainment: 

Describe entertainment provided: (e.g., name & location of 

restaurant, sporting or cultural event) 

Value of entertainment (excluding meals): 

Signature: 

Date: