Code of Ethics for
Principal Executives
&
Senior Financial
Officers
Procedures
Revised December 10, 2018
FRANKLIN TEMPLETON FUNDS
CODE OF ETHICS
FOR
PRINCIPAL
EXECUTIVES
AND
SENIOR
FINANCIAL OFFICERS
I.
Covered Officers and Purpose
of the Code
This code ethics
(the "Code") applies
to the Officers,
Financial and Principal Officer (the "Covered Officers," each of is set forth
in Exhibit of each investment company advised by a Franklin that is registered with the United
States & Exchange
(“SEC”)
"FT
Funds") for the purpose of
of
Principal
Executive
Principal
Officer
Accounting
whom
A)
Resources
subsidiary
andSecurities
Commission
(collectively,
promoting:
·
Honest
conduct,
including
of
apparent
conflicts
personal
·
Full,accurate,
reports
documents
files
the
public
made
·
Compliance
applicable
·
Thereporting
violations
to
appropriate
person
identified
·
Accountability
Each Officer will be to adhere to a high standard of business and must be
to that give rise to as as apparent conflicts
of interest.
Covered
expected
ethics
sensitive
situations
may
actual
well
*
Rule 38a-1 Act of 1940 (“1940 1940 (“Advisers Act”) and advisers of the and
under
the
Investment
Company
Act”)
and Rule
206(4)-7
under the
Investment Advisers
Act of
(together
the “Compliance Rule”) require registered
investment
companies
registered
investment
to,
among other things, adopt and implement
written policies
and procedures
reasonably
designed to prevent
violations
federal
securities
laws
(“Compliance
RulePolicies
Procedures”).
CONFIDENTIAL
INFORMATION.
This
document
is the
proprietary
product
ofInvestments.
It
may
NOT
distributed
outside
the company
unless
it is
non-disclosure agreement
and/or such
release
receives
by
an
FTI Chief Compliance
Officer.
Any
unauthorized
use,
reproduction
or transfer
document
is strictlyprohibited.
Franklin
TempletonInvestments
© 2014.
Rights
Reserved.
 |
II.
Other
Policies and Procedures
This Code shall
be the sole code of ethics the Funds for 406 of the Sarbanes-Oxley and the rules
and forms registered investment companies
adopted
bypurposes
of Section
Act
applicable
to
thereunder.
Franklin has adopted the Code
of Ethics and Business Conduct (“Business is applicable to all officers,
directors and employees
of Franklin including
Covered Officers. It the values, principles
and business
that guide the
provides a set of basic to guide officers,
and employees
regarding the minimum ethical
requirements expected of them. It supplements the values, and business conduct
identified in the Code and other existing
employee
Resources,
Inc.
separately
Conduct”),
which
Resources,
Inc.,
summarizes
practices
employee’s
businessconduct
and
alsoprinciples
directors
principles
policies.
Additionally, the Franklin
Templeton Funds separately adopted the FTI
Investments and Insider Trading Policy governing personal securities and other related
matters. Code for Insider for
that apply to the Covered
Officers and and
is part of this Code.
have
Personal
trading
The
Trading
provides
separate
requirements
others,
therefore
not
Insofar as other
policies or of
Inc., the Funds, the Funds’
adviser,
underwriter, or other service providers
govern or purport to govern the behavior
or activities are subject to this Code, they are by this Code to the extent that overlap or conflict the of this review these other documents or consult
with the of these to you.
procedures
Franklin
Resources,
principal
of
the
Covered Officers who
superceded
they
with
provisions
Code.
Please
the
Legal Department
if have questions regardingapplicability
policies
III.
Covered Officers Should Handle Ethically
Actual and Apparent Conflicts of Interest
Overview. A "conflict of interest" occurs a Covered
Officer's private interest
interferes the interests
of, or his or her service to, the FT Funds. For example, a conflict of interest arise if a Covered Officer, or a of his receives improper
benefits as a result of the FT Funds.
when
with
would
member
family,
personal
apposition
with
Certain of arise of the Covered Officers and the FT Funds and already are subject to conflict of
provisions in the Investment Company
Act of 1940 ("Investment Company
Act") and the Investment Act of 1940 ("Investment Act"). For example, Covered
Officers not individually engage in certain
as the or sale of or property) with the FT Funds of their status persons" of FT Funds. The FT and the investment advisers’ programs and procedures
are designed to prevent, or identify and correct, violations of these provisions. This Code does not,
and is not intended
to, repeat or replace these programs and procedures, and such conflicts outside
the parameters of this Code.
conflicts
interest
out
relationships
between
interest
Advisers
Advisers
may
transactions
(such
purchase
securities
other
because
as
"affiliated
the
Funds’
compliance
fall
of
Although typically
not an opportunity for improper personal
arise from, or as a result of, the the FT Funds, the investment advisers the fund of which the Covered Officers
are also employees. As a result,
Code the Covered Officers
in the course
of duties formally
for the FT Funds, for the adviser,
the administrator, or
presenting
benefit,
conflicts
contractual
relationship
between
and
administrator
officers
or
this
recognizes
that
will,
normal
their
(whether
|
for all
be involved in establishing policies
and implementing that will have different on the administrator and the FT The participation of Covered Officers
in such activities is inherent in between
the FT Funds, the and the administrator and is consistent the performance by the Covered
Officers of duties
as of the FT Funds.
if
in conformity with the provisions of Investment Company
and the Investment Act, such activities will be deemed
to have been handled In
it is the FT Funds'
Boards of ("Boards") that the Covered
Officers may also be officers
or employees of one or more other investment companies
by this or other
three),
decisions
effects
adviser,
Funds.
the
the
contractual
relationship
adviser,
with
their
officers
Thus,
performed
the
Act
Advisers
ethically.
addition,
recognized
by
Directors
covered
codes.
Other conflicts
of are covered
by the Code, even if such of interest are not subject
provisions in the Investment Company
Act and the Investment Advisers
Act. The following
list provides examples
of conflicts of
under the Code, but Covered
Officers should keep in mind that these examples are not exhaustive. The overarching is that the personal interest
of a Covered Officer should not be improperly before
the interest of the FT Funds.
interest
conflicts
to
interest
principle
placed
Each Covered
Officer must:
·
Not
personal
influence
personal
decisions
reporting
·
Not
the
action,
personal
the
benefit
FT
·
Not
employee
their
persons
reports
potential
violations
·
Report
following
affiliations
relationships:
1
o
alldirectorships
companies
companies
required
o
anybusiness
relationship
any
o
anybusiness
relationship
any
firm
related
issues
related
firm’s
the
and
o
anyinterest
(not
including
affiliates
Franklin
Resources).
These will be reviewed
by the Legal Department for compliance with the Code.
reports
There are some conflict
of interest situations should be approved
in writing by Franklin Resources General Counsel or
General Counsel, if material. Examples
of these
that
always
Deputy
include
2
:
·
Service
the
or
1
Reporting of these affiliations or other relationships shall be made by completing the annual and Officers Questionnaire and returning the questionnaire to
Resources Inc, General
Counsel or Deputy
General Counsel.
Directors
Franklin
2
Any activity
or relationship that present a conflict for a Covered
Officer may also present a conflict for the Covered
Officer
would
if a member of the Covered
Officer's immediate family engages in such an activity or has such a relationship. The Cover Person should also obtain written
approval by FT’s General Counsel
in such situations.
·
Theassociation.
·
TheCompany
prospective
business
entertainment
business
related,
appropriate
any
foregoing,
Resources
any
·
Any
employment
than
principal
·
Afinancial
interest
transaction
paid
effecting
transactions
selling
redeeming
an
·
FranklinResources
General
provide
the
next
IV.
Disclosure and Compliance
·
Each
requirements
the
·
Each
knowingly
others
about
Funds
outside
including
FT
directors
auditors,
regulators
self-regulatory
·
Each
responsibility,
administrator
promoting
fair,
accurate,
understandable
disclosure
reports
documents
with,
·
Itresponsibility
standards
imposed
applicable
V.
Reporting and
Accountability
Each Covered
Officer must:
·
Upon
affirm
understands
·
Annually
affirm
complied
·
Notify
Resources’
Deputy
promptly
knows
Code.
|
Code.
Franklin Counsel
and Deputy General
are responsible for applying this Code to specific situations in which questions are
under it have the authority
to interpret this in any particular However, the Independent Directors of the FT Funds will
any approvals or waivers by any Chief Executive
Officers of the Funds.
Resources’
General
Counsel
presented
and
Code
situation.
3
respective
consider
4
soughtThe FT Funds will these in enforcing this Code:
follow
procedures
investigating
and
·
FranklinResources
General
take
appropriate
investigate
reported
·
If,investigation,
or
take
·
Any
matter
believes
violation
reported
Independent
appropriate
·
IfIndependent
Directors
that
occurred,
inform
appropriate
which
consider
policies
procedures;
notification
of
·
TheDirectors
responsible
for
·
Any
Code
the
disclosed
5
VI.
Other Policies and Procedures
This Code shall be the sole code ethics by the FT Funds purposes
of Section 406 of the Sarbanes-Oxley and the rules forms to registered investment companies thereunder. Insofar
as
or procedures of the FT Funds, the FT Funds' advisers, principal
or other service
providers govern or purport to govern the behavior or activities of Covered Officers
who are subject to this Code, they are superseded by this Code to the extent that they overlap or conflict
the provisions of this Code.
The FTI Investments and Insider Trading
Policy, adopted by the FT Funds, FT investment advisers
and FT Fund’s
underwriter pursuant to 17j-1 under the Investment Company Act, the Code of and Business
Conduct and more detailed and procedures set forth FT’s Employee Handbook
are separate requirements applying to the Covered Officers
and others, and are not part of this
of
adopted
for
Act
and
applicable
other
policies
underwriter,
the
with
Personal
principal
Rule
Ethics
policies
in
Code.
3
Franklin Resources General Counsel and Deputy General
Counsel are authorized to consult, as appropriate, members
of the Audit Committee, counsel
to the FT Funds and counsel to the Independent Directors, and are encouraged to do so.
with
4
Item 2 of N-CSR defines as
approval by the registrant of a material
departure from a provision the code of
Form
"waiver"
"the
of
ethics" and "implicit must also be disclosed, as
registrant's failure to take action a reasonable
period of time
a material departure
from a provision of the code of ethics that has made known to an executive
officer" the registrant. See Part X.
waiver,"
which
"the
within
regarding
been
of
5
See Part X.
|
VII.
Amendments
Any amendments to this Code, other than amendments to Exhibit A, must be
or ratified by a majority
vote of the Funds’ a majority of directors.
approved
FT
Board
including
independent
VIII.
Confidentiality
All reports and records prepared
or pursuant to this will be and shall be and
accordingly. as otherwise required by law or
this Code, such matters shall not be disclosed to anyone other than the FT Funds’
Board and their
maintained
Code
considered
confidential
maintained
protected
Except
counsel.
IX.
Internal Use
The Code is intended for the internal
use by the FT Funds and does not an admission, by or on behalf of any FT Funds, as to any fact, or conclusion.
solely
constitute
circumstance,
legal
X.
Disclosure
on
Item 2 of Form N-CSR requires
a management investment company to whether,
as of the of the covered by the report,
it has a code of ethics that applies to the officer,
principal
officer, principal officer
or controller, or
similar
of whether these
employed by the registrant or a third
party. If the registrant has not adopted
such a code of ethics,
it must explain why it has not done so.
registered
disclose
annually
end
period
adopted
registrant's
principal
executive
financial
accounting
persons
performing
functions,
regardless
officers
are
The must (1) file with the SEC a copy of the code as an exhibit to its annual
(2) post text of the code on Internet website
and in most
registrant
also:
report;
the
its
disclose,
its
recent on Form N-CSR,
its Internet address
and the that it posted
the code on its Internet
website; or (3)
in its most
report on Form N-CSR to provide to any person
charge, upon request,
a copy of the code and explain
the manner in which such request may be made. is also of amendments to, or waivers
(including implicit waivers)
from, a provision of the code in annual on Form N-CSR
report
fact
has
undertake
recent
without
Disclosure
required
the
registrant's
report
or on its If the to satisfy the requirement to disclose and waivers by posting on its it will be
to disclose address
and this
website.
registrant
intends
amendments
such
information
website,
required
its
Internet
intention.
The Legal
Department shall be for
that:
responsible
ensuring
·
aannual
report;
·
anyregistrant's
In the event that the
is
or is to be incorrect, Legal
Department shall promptly
file such with SEC as an amendment to Form N-CSR.
foregoing
disclosure
omitted
determined
the
information
the
In such an
the Fund Chief
Compliance Officer shall
review the Code and propose
such to the Code as are or prevent
reoccurrences.
event,
changes
necessary
appropriate
to
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EXHIBIT A
Persons Covered
by the Franklin
Funds Code of Ethics
Templeton
December 2018
FRANKLIN GROUP OF FUNDS
Edward
Perks President
and
Chief Executive Officer
Investment
Management
Rupert
H. Johnson, Jr. Chairman
of the
Board and
Vice President– Investment
Management
Taylor President
and
Chief Executive Officer
Investment
Management
Sonal
Desai) President
and
Chief
Executive
Officer
Investment
Management
Matthew
Hinkle Chief Executive Officer
–
Finance
and
Administration
FRANKLIN MUTUAL SERIES
FUNDS
Peter Langerman Chief
Executive Officer
–
Investment Management
Matthew
Hinkle Chief Executive Officer
– Finance
and
Administration
Robert G. Kubilis Chief
Financial Officer and Chief Accounting Officer
FRANKLIN ALTERNATIVE STRATEGIES FUNDS
Mat S. Gulley Chief
Executive Officer
–
Investment
Management
Matthew Hinkle Chief
Executive
Officer
– Finance
and
Administration
Robert G. Kubilis Chief
Financial Officer and Chief Accounting
Officer
TEMPLETON
GROUP OF FUNDS
Manraj
S. Sekhon President and
Chief
Executive Officer
Investment
Management
Michael
Hasenstab,
Ph.D.President
and Chief Executive Officer
Investment
Management
Boersma President
and
Chief Executive Officer
Investment
Management
Matthew
Hinkle Chief Executive Officer
– Finance
and
Administration
Robert G. Kubilis Chief
Financial Officer, Chief Accounting Officer and Treasurer
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Exhibit B ACKNOWLEDGMENT
FORM
Franklin Templeton Funds Code of Ethics
For Principal Executives and Senior Financial Officers
Instructions:
1.
all of this form.
Complete
sections
2.
the
form, sign, and date.
Print
completed
3.
Submitwithin
th
ofsubsequent
Inter-office mail:
Code
of Ethics Global
Compliance SM-920/2
Administration,
Fax:
(650)
312-5646
E-mail: of Ethics
& Requests (internal (external address)
Code
Inquiries
address);
lpreclear@franklintempleton.com
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Covered |
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Title: |
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Department: |
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Location: |
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Certification |
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To: Franklin Resources General Counsel, Legal
Department
I reading the
Templeton of Ethics for and Financial (the “Code”). I comply fully all provisions of the Code to the extent they apply to during the
of employment. I further understand
and acknowledge that any of the Code may subject me to disciplinary action,
including of employment.
acknowledge
receiving,
and
understanding
Franklin
Fund’s
Code
Principal
Executive
Officers
Senior
Officers
will
with
me
period
my
violation
termination
Signature Date
signed