pgiprei-code.htm - Generated by SEC Publisher for SEC Filing


PRINCIPAL GLOBAL INVESTORS, LLC
PRINCIPAL REAL ESTATE INVESTORS, LLC
NORTH AMERICA


CODE OF ETHICS

February 14, 2011


Principal Global Investors, LLC (“PGI”) and Principal Real Estate Investors, LLC
(“PrinREI”) (collectively, the “Advisers”) have adopted this Code of Ethics (the “Code”). The
principal objectives of the Code are to provide policies and procedures consistent with
applicable laws and regulations, including Rule 204A-1 under the Investment Advisers Act of
1940; and to prevent conflicts of interests or the appearance of such conflicts when officers,
directors, supervised persons, employees and other persons of the advisers own or engage
in transactions involving securities.

Employees of the Advisers are also subject to the Principal Financial Group
Corporate Code of Business Conduct and Ethics which can be found on the Principal Global
Investors Compliance Portal of the Inside The Principal® intranet site. Employees are
reminded that they are also subject to other policies including policies on insider trading, the
handling of all internally distributed proprietary and confidential information, and information
barriers, among others.

Responsibility for this Code is vested in the Chief Compliance Officer of the Adviser.
However, the responsibility for implementing this Code on a day-to-day basis falls on all
employees and especially staff that are in supervisory and management roles. Employees
with questions are strongly urged to consult with the Compliance Department prior to taking
the action in question. The following are the primary Compliance contacts for questions
regarding the Code:

*PGI Senior Compliance Analyst*	*PGI Compliance Associate*
Niki Rathert	Wynell Kisner
515-362-1412	515-247-5597
Rathert.Niki@principal.com	Kisner.Wynell@principal.com

*PGI North America Chief Compliance Officer*	*PGI Global Chief Compliance Officer*
Minoo Spellerberg	Jeffrey Hiller
515-248-3082	515-235-5737
Spellerberg.Minoo@principal.com	Hiller.Jeffrey@principal.com

*PFG Chief Compliance Officer*
Betsy Happe
515-362-0282
Happe.Betsy@principal.com


TABLE OF CONTENTS

					Page
I.	Definitions				4
	A.	Access Person			4
	B.	Advisers			4
	C.	Beneficial Ownership			4
	D.	Covered Accounts			4
	E.	Covered Associate			4
	F.	Covered Securities			4
	G.	Employee			5
	H.	Federal Securities Laws			5
	I.	Investment Club			5
	J.	Portfolio Managers			5
	K.	Private Investments			5
	L.	Reportable Fund			5
	M.	Reportable Security…			5
	N.	Master Security List			5
	O.	Security			5
	P.	Supervised Person			5

II.	General Principles				6
	A.	Statement of Purpose and General Principles			6
	B.	Standards of Business Conduct			6
	C.	Promptly Report Violations of the Code			6
	D.	Statutory Grounds for Disqualification
		from Employment			7

III.	Personal Securities Transactions – Rules				8
	A.	Restricted and Prohibited Transactions			8
	B.	Exempt Securities and Transactions			8
		1.	Exempted Securities		8
		2.	Exempted Transactions		9
	C.	Specific Rules Applicable to Portfolio Managers and
		Investment Personnel			9
		1.	Seven-Day Blackout Periods		9
		2.	Purchasing an Investment for a Fund/Account
			that is a Personal Holding		10
		3.	Establishing Positions Counter to Fund/
			Account Positions		10
	D.	Special Rules Applicable to Directors of the Advisers			10
	E.	Principal Real Estate Investors Access Persons –
		Additional Rules			11
	F.	Personal Trading Monitoring System			11
	G.	Pre-Clearance of Securities Transactions			11
		1.	How to Pre-Clear		12
			a.	On-line Pre-Clearance	12
			b.	Compliance Dept. Pre-Clearance	12
		2.	Standard of Review for Pre-Clearance of Trades		12
	H.	Purchase of Private Investments			12
	I.	Purchase and Sale of PFG Stock and Proprietary Funds… 13


I.	DEFINITIONS

A.	Access Person: Any officer, director, employee or other person of the Advisers
	(including any of the Advisers’ supervised persons) who has access to nonpublic
	information regarding any clients’ purchase or sale of securities; has access to
	nonpublic information regarding the portfolio holdings of any advisory client; is
	involved in making securities recommendations to clients; or has access to such
	recommendations that are nonpublic. Positions held by consultants, contractors,
	temporary employees, interns, co-op students and PFG HR and Legal staff
	supporting the Advisers are deemed an Access Person unless otherwise evaluated
	by the Compliance Department not to have access or potential access to nonpublic
	information, as described above. *All Employees of the Advisers are deemed to be*
	*“Access Persons” under this Code.* (“Access Person” and “Employee” have the
	same meaning and are used interchangeably in the Code).

B.	Advisers: means Principal Global Investors, LLC and Principal Real Estate Investors,
	LLC.

C.	Beneficial Ownership: shall be interpreted in the same manner as it would be under
	Rule 16a-1(a)(2) under the Securities Exchange Act of 1934 when determining
	whether a person is a beneficial owner of a security.

	For example, the term “Beneficial ownership” shall encompass: securities in the
	person’s own account(s); securities owned by members of the person’s immediate
	family sharing the same household; a person’s proportionate interest in the portfolio
	of securities held by a partnership, trust, corporation or other arrangements; and
	securities a person might acquire or dispose of through the exercise or conversion of
	any derivative security (e.g. an option, whether presently exercisable or not). See
	Covered Accounts.

D.	Covered Accounts: shall include any account that an Access Person has, or
	acquires any direct or indirect beneficial ownership in a security held in the account.
	Generally, an Access Person is regarded as having a beneficial ownership of
	securities held in an account in the name of: (1) the individual; (2) a spouse, minor
	child, immediate family member or dependant of the Access Person sharing the same
	household; (3) a relative sharing the same household; (4) another person (i) if the
	Access Person obtains benefits substantially equivalent to ownership of the
	securities; (ii) can obtain ownership of the securities immediately or at some future
	time (i.e. inheritance); or (iii) can have investment discretion or otherwise exercise
	control.

E.	Covered Associate: shall include executive officers and employees who solicit
	government entities for the investment adviser, along with those who directly or
	indirectly supervise such employees.

F.	Covered Securities: shall include all securities, any option to purchase or sell, and
	any securities convertible into or exchangeable for such securities. For example,
	covered securities include but are not limited to individual securities, open-end and
	closed-end mutual funds, exchange traded funds and unit investment trusts. Certain
	securities are exempted from this definition. See Exempted Securities at Section
	III.B.1.


G.	Employee: shall have the same meaning as Access Person.

H.	Federal Securities Laws: means the Securities Act of 1933, as amended, the
	Securities Exchange Act of 1934, as amended, the Investment Company Act of 1940,
	as amended, the Investment Advisers Act of 1940, as amended, (and all rules
	adopted under those Acts) the Sarbanes-Oxley Act of 2002, Title V of the Gramm-
	Leach-Bliley Act, the Bank Secrecy Act, and all rules adopted under any of these
	statutes by the Securities and Exchange Commission or the Department of the
	Treasury.

I.	Investment Club: means a group of individuals who combine their funds for the
	purpose of making investments and advancing their investment education.

J.	Portfolio Managers: means individuals entrusted with the direct responsibility and
	authority to make investment decisions for or affecting the accounts of the Advisers’
	clients.

K.	Private Investments - Generally, private investments involve the sale of securities to
	a relatively small number of qualified investors in a private transaction, rather than
	through an exchange or over the counter market. Private investments may not have
	to be registered with the Securities and Exchange Commission and in many cases
	detailed financial information is not disclosed. Examples include, but are not limited
	to hedge funds, limited partnerships, and private equity transactions.

L.	Reportable Fund: means (i) any fund for which the Advisers serves as an investment
	adviser as defined by the Investment Company Act of 1940; or (ii) any fund whose
	investment adviser or principal underwriter controls the Advisers, is controlled by the
	Advisers, or is in common control with the Advisers.

M.	Reportable Security: shall have the meaning set forth in Section 202(a)(18) of the
	Investment Advisers Act, except for securities explicitly exempted by the Code in
	Section III.B.1.

N.	Master Security List: includes the names of all securities that the Advisers (1) is
	currently buying or selling, and (2) all securities currently held in client accounts.

O.	Security: shall have the meaning set forth in Section 202(a)(18) of the Investment
	Advisers Act including, but not limited to fixed income securities, equity securities,
	securities based on indices, I-Shares, exchange traded funds (ETF), UIT, options and
	limited or private placement offerings of securities, and other derivative instruments.
	Derivative instruments would include commodity, credit, currency, equity, interest rate
	and volatility.

P.	Supervised Person: is any officer, director (or other person occupying a similar
	status or performing similar functions), or employee of the Advisers, or other person
	who provides investment advice on behalf of the Advisers and is subject to the
	supervision and control of the Advisers.


II.	GENERAL PRINCIPLES

	A.	STATEMENT OF PURPOSE AND GENERAL PRINCIPLES

	Principal Global Investors, LLC and Principal Real Estate Investors, LLC (collectively
	the “Advisers”) have adopted this Code of Ethics (the “Code”). The principal
	purposes of this Code are to:

		Provide policies and procedures consistent with applicable laws and
		regulations, including Rule 204A-1 under the Investment Advisers Act of 1940
		and Rule 17j-1 under the Investment Company Act of 1940; and

		Prevent conflicts of interests or the appearance of such conflicts when
		officers, directors, supervised persons, employees and other persons of the
		advisers own or engage in transactions involving securities.

	Employees of the Advisers are also subject to the Principal Financial Group (PFG)
	Corporate Code of Business Conduct & Ethics and other PFG policies which can be
	found on the Principal Global Investors Compliance Portal of the Inside The
	Principal® intranet site.

	B.	STANDARDS OF BUSINESS CONDUCT

	The following standards of business conduct shall govern personal investment
	activities and interpretation and administration of this Code:

	•	The interests of advisory clients must be placed first at all times;

	•	All personal securities transactions must be conducted consistent with this
		Code and in such a manner as to avoid any actual or potential conflict of
		interest or any abuse of an individual’s position of trust and responsibility;

	•	Supervised persons should not take advantage of their positions; and

	•	Supervised persons must comply with applicable federal securities laws.

	The Code does not attempt to identify all possible conflicts of interests, and literal
	compliance with each of its specific provisions will not shield supervised and/or
	advisory personnel from liability for personal trading or other conduct that violates a
	fiduciary duty to advisory clients.

	C.	PROMPTLY REPORT VIOLATIONS OR POSSIBLE VIOLATIONS
		OF THE CODE

	The Investment Advisers Act requires all Employees of an investment adviser “to
	report any violations of your code of ethics promptly to your chief compliance officer
	or other persons designated.” Accordingly if you commit a violation or become aware
	of a violation you must promptly report this to the Advisers’ Chief Compliance Officer
	or their designee contacts listed on the cover page of the Code. Those contacts shall
	promptly report any violations to the Chief Compliance Officer.


In addition, staff can also utilize the PFG “Whistle Blower” process found at:
http://inside.principal.com/gfr/brc/busprac/whistleblower.shtm. Any information passed
through the Whistleblower process will remain confidential.

In addition, the Ethics Hotline can be used at 1-866-858-4433. The Ethics Hotline is
staffed 24 hours a day, seven days a week.

D.	STATUTORY GROUNDS FOR DISQUALIFICATION FROM
	EMPLOYMENT

The Advisers mandates that no officer, director or employee of the Adviser may
become or continue to remain an officer, director or employee without an exemptive
order issued by the U.S. Securities and Exchange Commission if such director, officer
or employee within the past thirteen years or during the course of employment:

•	has been charged with, convicted of, or plead guilty or no contest to any
	felony or misdemeanor or of a substantially equivalent crime by a foreign court
	of competent jurisdiction involving the purchase or sale of any security, the
	taking of false oath, the making of a false report, bribery, perjury, burglary, or
	conspiracy to commit such offense, or has been convicted of any crime that is
	punishable by imprisonment for 1 year or more years that is not described
	above;

•	has been charged with, convicted of, or plead guilty or no contest to any
	felony or misdemeanor or of a substantially equivalent crime by a foreign court
	involving the purchase or sale of any security; or arising out of their conduct
	as an underwriter, broker, dealer, investment adviser, municipal securities
	dealer, government securities dealer, transfer agent or entity or person require
	to register under the U.S. Commodity Exchange Act, or as an affiliated
	salesman or employee of any investment company, bank, insurance company
	or entity or person required to be registered under the Commodity Exchange
	Act; or

•	is or becomes permanently or temporarily enjoined by any court from (i) acting
	as an underwriter, broker, dealer, investment adviser, municipal securities
	dealer, transfer agent, or entity or person required to be registered under the
	U.S. Commodity Exchange Act, or as an affiliated salesman or employee of
	any investment company, bank, insurance company or entity or person
	required to be registered under the Commodity Exchange Act; or (ii) engaging
	in or continuing any conduct or practice in connection with any such activity or
	in connection with the purchase or sale of any security.

It is your obligation to immediately report any conviction or injunction falling within the
foregoing provisions to the Chief Compliance Officer of the Advisers (or their
designee).


III.	PERSONAL SECURITIES TRANSACTIONS RULES

	A.	Restricted and Prohibited Transactions

	The following restrictions and limitations (unless otherwise exempted) govern
	Personal Securities Transactions for all Employees/Access Persons:

	1.	Pre-clearance approval of all trades is valid for 2-business days. If the trade is
		not executed or completed within 2-business days (counted as the current
		business day and the next business day) of approval, a new pre-clearance
		approval will be required on the third day. This applies to all market and limit
		orders, good-till-cancelled orders, and stop loss orders.

	2.	No Access Person may acquire any security in an initial public offering (“IPO”).

	3.	No Access Person may sell short any security on the Master Security List.

	4.	No Access Person may participate in Investment Clubs.

	5.	Reportable Securities that are purchased must be held for 30-calendar days
		(counted as 30 full calendar days not including the trade date) prior to sale. If
		sold before the 30-calendar day holding period, any profits realized (or loss
		avoided) on the sale of a covered security prior to the 30-calendar day
		holding period must be disgorged to a charitable organization designated by
		the Advisers.

	6.	Reportable Securities sold may not be purchased at a lower price until at least
		30-calendar days from the sale trade date.

	7.	No option may be purchased or written if the expiration date is less than 30-
		calendar days from the date of purchase. No option position may be closed
		less than 30-calendar days from the date it is established.

	8.	An Access Person may not be allowed to purchase or sell a Security at all, at
		the discretion and guidance of the Chief Compliance Officer of the Advisers.

	B.	Exempt Securities and Transactions

	1.	Exempted Securities
		The securities listed below are exempt from the pre-clearance requirement,
		the initial, quarterly and annual reporting requirements and holding periods:

		a.	Direct Obligations of the Government of the United States
		b.	Banker’s acceptances
		c.	Bank certificates of deposit
			(Note: Brokered CDs offered by a financial intermediary are not exempt
and are Reportable Securities that require pre-clearance.)
		d.	Commercial paper
		e.	High quality short-term debt instrument, including repurchase agreements
		f.	Shares issued by money market funds


		g.	Shares issued by open-end mutual funds other than funds advised or sub-
			advised by the Advisers or an affiliate of the Advisers and proprietary
			funds. (Exemption is applicable to funds used in 529 Plans which may be
			registered as municipal securities but only offer open-end mutual funds or
			securities designed to mirror the structure of open-end mutual funds as
			underlying investment options. Self-managed 529 Plans available in some
			states may be reportable depending on the investment product options.)
			(Note: Exchanged Traded Funds (ETF) and I-Shares and Closed-end
			Mutual Funds are not exempt and are Reportable Securities that require
			pre-clearance. See Section I.E. Covered Security.)
		h.	Shares issued by unit investment trusts (“UIT”) that are invested
			exclusively in one or more open-end mutual funds, none of which are
			advised or sub-advised by the Advisers or an affiliate of the Advisers.
			(Note: Unit investment trusts (“UIT”) that are not invested exclusively in
			one or more open-ended mutual funds are not exempt and are Reportable
			Securities that require pre-clearance. See Section I.E. Covered Security.)

	2.	Exempted Transactions
		The transactions listed below are exempt from the pre-clearance requirement

		a.	Transactions in open-end mutual funds advised or sub-advised by the
			Advisers or an affiliate of the Advisers.
		b.	Transactions in Proprietary funds (including Principal mutual funds
			underlying principal variable life and variable annuity contracts).
		c.	Transactions in Principal stock. However, see requirements in Section III.
		d.	Securities acquired through an employer-sponsored automatic payroll
			deduction plan. Initial account set-up of brokerage self-directed plan must
			be disclosed but ongoing purchases do not have to be pre-cleared.
			However, all sales must be pre-cleared and reported.
		e.	The acceptance of stock dividends resulting from securities already
			owned under a dividend reinvestment plan or in an automatic investment
			plan for the purchase of securities already owned. (Note: the initial
			purchase or establishment of an automatic investment plan or dividend
			investment plan must be pre-cleared.)
		f.	Purchases or sales which are non-volitional on the part of the Access
			Person
		g.	Transactions in an account over which the Access Person has no direct
			or indirect influence or control (e.g. assignment of management discretion
			in writing to another party.

C.		Specific Rules Applicable to Portfolio Managers and Investment
		Personnel Authorized to Trade on Client Accounts

	1.	Seven-Day Blackout Periods for Portfolio Managers/Investment
		Personnel Authorized to Trade on Fund/Account. No portfolio
		manager/investment personnel authorized to trade on a Fund/managed
		account may purchase or sell a security for a personal account in which
		he/she has direct or indirect Beneficial ownership within 7-calendar days
		before and after a client account that he/she manages, advises or executes
		trades, trades in that security. (Note: the counting of the 7-calendar day
		period does not include the trade date. The full 7 days prior to and after the
		trade date are included in the Blackout Period.)


2.	Purchasing an Investment for a Fund/Account that is a Personal
	Holding. A portfolio manager/investment personnel authorized to trade on a
	Fund/managed accounts who are purchasing or selling an investment for a
	Fund/managed account that is also a personal holding of the portfolio
	manager/investment personnel in a Covered Account shall disclose such
	holding to his/her supervisor and the Compliance Department before making
	such investment for the Fund/managed account. A portfolio
	manager’s/investment personnel’s holdings, however, shall have no affect on
	the Fund/managed account’s ability to trade. Any purchase or sale for the
	portfolio must then be reviewed and approved by a Portfolio
	Manager/Investment Personnel who does not have an interest in the Security
	or issuer and such review must be documented in writing and maintained.

3.	Establishing Positions Counter to Fund/Account Positions. No portfolio
	manager/investment personnel authorized to trade on a Fund/managed
	account may establish a long position in his/her personal account in a security
	if the Fund/managed account for which he/she has investment authority
	maintains a position that would benefit from a decrease in the value of such
	security. For example, the portfolio manager/investment personnel would be
	prohibited from establishing a long position if (1) the Fund/managed account
	holds a put option on such security (aside from a put purchased for hedging
	purposes where the Fund/managed account holds the underlying security); (2)
	the Fund/managed account has written a call option on such security; or (3)
	the Fund/managed account has sold such security short, other than “against-
	the-box.”

	No portfolio manager/investment personnel may purchase a put option or
	write a call option where a Fund/managed account for which such person has
	investment authority holds a long position in the underlying security.

	No portfolio manager/investment personnel may short sell any security where
	a Fund/managed account for which such person has investment authority
	holds a long position in the same security or where such Fund/managed
	account otherwise maintains a position in respect of which the Fund/managed
	account would benefit from an increase in the value of the security.

D.	Special Rules Applicable to Directors of the Advisers

Any Director of an affiliated adviser is considered an Access Person of that adviser
and subject to their Code of Ethics as a matter of presumption. Any Director of the
Advisers who also serves as a Director of an affiliated adviser shall be examined with
regard to the affiliated adviser for their access to the affiliated advisers’ nonpublic
information regarding any clients’ purchase or sale of securities; access to nonpublic
information regarding the portfolio holdings of any advisory client; is involved in
making securities recommendations to clients; or access to such recommendations
that are nonpublic as to each adviser of which the Director is a member of the Board.
To the extent that such Director does not have such access to the affiliated adviser,
that Director may be exempt from pre-clearance of transaction after a full examination
and written documentation of the findings.


E.	Principal Real Estate Investors Access Persons – Additional
	Rules

No Employee of PrinREI or Access Person of the Advisers that has access to PrinREI
nonpublic information may purchase or sell a U.S real estate investment property
without the pre-approval of a PrinREI Investment Committee member and the
Compliance Department. See Attached Schedule A – U.S. Real Estate Investment
Property Approval Request Form.

Note the following property types are exempt from reporting:
•	Single Family Residential property
•	Vacation Residential property
•	Multi-Family Residential Complex property with less than 20 units
	(Examples: apartments, condos)
•	Farmland property zoned and operated as agricultural that is not adjacent to
	properties owned, developed or considered to be developed by PrinREI

F.	Personal Trading Monitoring System

SunGard Personal Trading Assistant (SunGard PTA) is an intuitive browser-based
application available on The Principal’s intranet that automates compliance with
personal securities trading regulations and the Advisers’ Code. The functionality
spans various areas of personal securities trading, which includes pre-trade
authorization/post-trade reconciliation/ensuring comprehensive documented
compliance with personal securities trading regulations.

Online accessibility is available on The Principal’s intranet only, which can be done
outside of the office with a company laptop with VPN capability or Citrix. For Citrix
users, a RAMS request will need to be submitted for you to be added to the AD
Group “WTS PGI SunPTA”.

G.	Pre-Clearance of Securities Transactions

All Access Persons must receive pre-clearance approval of the full quantity for
all Reportable Securities transactions from the Advisers’ Compliance Department
prior to entering into any transaction. (Note: it is advised to overestimate if the exact
quantity is not known at the time of the pre-clearance.) Pre-clearance approval is
valid for 2-business days. If the trade is not executed or completed within 2-business
days of approval, a new approval will be required on the third day. This applies to all
market and limit orders, good-til-cancel orders, and stop loss orders.

Pre-clearance is not required for Exempted Securities (See Section III.B.1.) or
Exempted Transactions (See Section III.B.2).

When seeking to purchase or sell Reportable Securities for your personal account
you should pay particular attention to the following most frequent Code violations
noted by the Compliance Department, but still must observe all provisions of the
Code:
•	Failure to obtain pre-clearance approval for a trade;
•	Trading after the pre-clearance approval period of 2-business days has
	expired;


•	Trading more shares than pre-cleared;
•	Submitting a pre-clearance after the trade was executed; and
•	Failure to obtain pre-clearance approval for ETF, UIT, Broker CD or Private
	Investment transactions.

	1. How to Pre-Clear a Trade. Pre-clearance of a trade can be accomplished
	in one of two ways:

	a.	On-line Pre-Clearance – A pre-clearance must be filed online within
		SunGard PTA prior to executing a trade. Approval/denial will be
		provided from the system immediately.
		•	Approval is valid for 2-business days. Approved trades must
			be executed within 2-business days from the date the pre-
			clearance was approved
		•	Denied trades must not be executed

	b.	Alternative Methods of Pre-Clearance – Should an Access Person
		not have access to SunGard PTA available on The Principal intranet
		site via VPN or Citrix, they may call or email to obtain trade pre-
		clearance by:
		•	The Compliance Department
		•	A Proxy
			A proxy is a person who has been permitted to act on behalf of
			another person. An Advisers Access Person can be made a
			proxy for another Access Person. The Compliance Department
			can setup the proxy relationship upon request.

		Access Persons must not execute the trade until they have received a
		confirmation from the Compliance Staff that the pre-clearance was
		approved. When seeking to pre-clear through alternative methods,
		Access Persons are required to provide the following information:
		•	Broker account number
		•	Name of Security
		•	Security ticker symbol or Cusip
		•	Quantity
		•	Buy/sell

	2. Standard of Review for Pre-Clearance of Trades

	The Compliance Department has the authority and discretion to determine
	whether to grant or deny pre-clearance of a trade. Access Persons may be
	limited in the number of shares or principal amount of a Security listed on the
	Master Security List. They also may not be allowed to purchase or sell a
	Security at all (See Section III.A.8.).

H.	Purchase of Private Investments

Private investments of any kind may only be acquired with prior approval of the
Access Person’s supervisor and the Chief Compliance Officer (or their designee).
Any Access Person wishing to request approval for private investments must


complete a Private Investments Approval Request Form. See Attached Schedule C
- Private Investment Approval Request Form.

I.	Purchase and Sale of PFG Stock and Proprietary Funds

Holdings and transactions in PFG stock are subject to the initial, quarterly and annual
reporting requirements as well as the 30-calendar day holding period.

The restrictions imposed by Principal Financial Group and other designated persons
in connection with transactions in PFG stock are in addition to this Code and must be
observed to the extent applicable. Employees are responsible for understanding
*whether they are subject to the Corporate Policy and Rules on trading in PFG*
*stock. Please refer to the following links:* Corporate policy on the trading of PFG
stock.http://inside.principal.com/gfr/brc/busprac/insidertradingstatement.shtm

Please note, pursuant to the PFG corporate insider trading policy, the following
activities with respect to Company securities are prohibited by all Employees of the
member Companies of the PFG and family members sharing their households:

•	Purchasing Company securities "on margin" (i.e., with the proceeds of a loan from
	a brokerage firm when the loan is secured by Company securities), except for the
	exercise of employee stock options.
•	Short sales (selling stock that is borrowed in anticipation of a drop in price).
•	Trading in put or call options.

Corporate HR Benefit Plans:

The following PFG Plans are considered Covered Accounts and will be monitored by
the Compliance Department. There is no action required by Access Persons to
create these accounts within SunGard PTA, as we will be receiving information
directly from HR Benefits. The Compliance Department will monitor accordingly.

	•	PFG Employee Stock Purchase Plan (ESPP)
	•	PFG Excess Plan
	•	PFG 401(k) Plan

The following are not considered Covered Accounts and thus are not subject to
reporting or holding periods. Please note, once vested/exercised and PFG stock is
held within your personal brokerage account (and no longer held with the Plan
Administrator), the Security becomes reportable at that time.

	•	Restricted Stock Units (RSU)
	•	Stock Options Awards
	•	Stock Options – Broadbased Options
	•	Performance Share Awards

Principal Proprietary Funds Reminder:

Proprietary Funds, which including Principal Mutual Funds and underlying investment
sub-accounts within Principal Variable Life and Variable Annuity contracts are
reportable. Please contact the Compliance Department for assistance in finding and
entering these Reportable Securities within SunGard PTA.


IV.	REPORTING REQUIREMENTS

	A.	Initial Holdings Report

	All Access Persons must, within 10-calendar days of the date of their hire or
	appointment as an Access Person, furnish the Compliance Department an Initial
	Holdings Report current as of a date no more than 45-calendar days prior to the date
	the person becomes an Access Person containing the following information: (i) the
	name, type, number of shares, exchange ticker or CUSIP number, and principal
	amount of each Security in which the Access Person had any direct or indirect
	Beneficial Ownership at the time the report was prepared; (ii) the name and address
	of the broker, dealer, bank or firm at which the Access Person maintains any Covered
	Account during the period covered in which securities were held for the direct or
	indirect benefit of the Access Person; (iii) the account number of any account
	described above; and (iv) the date the report was prepared.

	B.	Quarterly Transactions Report

	Access Persons shall file a report with the Compliance Department listing all of their
	personal Securities transactions (except Exempted Transactions) during the previous
	calendar quarter in any Security (except Exempted Securities) in which such person
	has acquired any direct or indirect Beneficial Ownership. The report shall be in a
	format as required by the Compliance Department and filed within 30-calendar days
	following the end of such calendar quarter. The report shall contain the following
	information:

	•	The date of the transaction(s), the title, exchange ticker or Cusip number,
		interest rate and maturity date (if applicable), number of shares, and principal
		amount of each Security involved;
	•	The nature of the transaction (e.g., purchase, sale or any other type of
		acquisition or disposition);
	•	The price at which the transaction was effected;
	•	The name of the broker, dealer, or bank with or through which the transaction
		was effected; and
	•	The date the report is submitted by the Access Person.

	C.	Annual Holdings Report

	Access Persons must submit an Annual Holdings Report to the Compliance
	Department using a statement or report that is dated no more than 45-calendar days
	prior to the date the report is submitted, containing the following information: (i) the
	name, type, number of shares, exchange ticker or CUSIP number, and principal
	amount of each Security (except Exempted Securities) in which the Access Person
	had any direct or indirect Beneficial Ownership at the time the report was prepared;
	(ii) the name and address of the broker, dealer, bank or firm at which the Access
	Person maintained any Covered Account during the period covered in which
	Securities were held for the direct or indirect benefit of the Access Person; (iii) the
	account number of any account described above; and (iv) the date the report was
	prepared.


Access Persons will be required on an annual basis within 30-calendar days of the
request to verify that their holdings are complete and accurate in the SunGard PTA
system.

D.	Initial and Annual Certification of Compliance

The Chief Compliance Officer (or their designee) shall ensure that each Access
Person receives a copy of this Code, any material amendment thereto and a written
acknowledgement of receipt to be signed and returned to the Chief Compliance
Officer (or their designee). The Code is also available to all Access Persons on The
Principal intranet site.

All Access Persons will be required within 10-calendar days of their appointment as
an Access Person and annually thereafter to certify in writing that they have read and
understand the Code and the Insider Trading Policy (“Policy”) and its applicability to
them, that they have complied with the requirements of the Code and Policy, and that
they have disclosed or reported all personal Securities transactions and/or Covered
Accounts as required by the Code.

E.	Broker Account Reporting

1.	New Accounts

All Access Persons must, within 2-business days of opening a new Covered
Account, report the new broker account within the SunGard PTA system. The
following information will need to be provided: the name of the broker, dealer,
bank or firm where the Covered Account is held, the identifying number and name
on the Covered Account, and the date it was established. Entry of this new
broker account will serve as consent to obtain the records of your Covered
Account for monitoring as required by Rule 204A-1 under the Investment Advisers
Act of 1940. Upon notification of the new broker account within SunGard PTA,
the Compliance Department will send a 407 Letter Request directing the broker,
dealer, bank or firm with which an Access Person has a Covered Account to
furnish the Advisers’ Compliance Department on a timely basis, duplicate copies
of periodic statements and trade confirmations of all personal Securities
transactions.

2.	Discretionary Managed Accounts

Access Persons must report all Covered Accounts over which the Access Person
has no direct or indirect influence or control (e.g., assignment of management
discretion in writing to another party). The account must be reported to the
Compliance Department prior to opening. The Access Person will be required to
submit holding reports as directed by the Code. This provision may be satisfied
by providing a copy of an annual statement in lieu of reporting through the
SunGard PTA system. The Access Person must provide the PGI Compliance
Department with acceptable evidence that the investment adviser or other
financial institution acts as discretionary adviser at the time the account is
reported. (Note: discretionary managed accounts are exempted from the 30-day
holding period, quarterly transaction reports and from the prohibition on acquiring
initial public offerings.)


V.	POLITICAL CAMPAIGN CONTRIBUTIONS

The Advisers are subject to SEC, state and local laws regulating personal political campaign
contributions (“political contribution”) that are in place to inhibit “pay-to-play” practices which
occur when government officials¹award contracts to individuals and organizations in
exchange for political contributions. Pay-to-play rules are designed to restrict personal
political campaign contributions to government officials who are in a position to influence the
award of advisory business. Consequences to the Advisers for violation of these laws can
be severe, such as not receiving compensation for advisory services from a governmental
client (current or prospective) for two years.

Pay-to-play rules are complicated and vary from jurisdiction to jurisdiction. Restrictions and
reporting requirements of political contributions depend on the facts of a particular situation
and respective jurisdiction and/or client.

Rule 206(4)-5 of the Advisers Act contains several prohibitions and the Advisers would like to
highlight the following notable provisions:

	•	Two year “Time-Out” of Adviser Compensation
		Advisers can not be compensated for advisory services provided to a
		governmental client (current or prospective) following a prohibited political
		contribution to a governmental official or candidate.

	•	Two year “Look-back” Period for Covered Associates
		Advisers must look-back in time to determine whether a Covered Associate
		has made a triggering prohibited political contribution within the previous two
		years for Covered Associates who solicit clients, and six months for new
		Covered Associates who do not solicit clients.

	•	Ban on “Bundling”
		Advisers and Covered Associates are prohibited from bundling – i.e. soliciting
		from a person or PAC contributions to officials of governmental entities to
		which the Advisers seeks to provide investment advisory services.

	•	Ban on Third-Party Solicitors
		Advisers are prohibited from using third-party placement agents and solicitors
		who are not themselves “regulated persons” subject to pay-to-play restrictions
		on political contributions.

Regardless of whether a particular jurisdiction has a pay-to-play law, employees should
never provide campaign contributions with the intent to obtain or retain business or to
influence any other official action. Rule 206(4)-5 of the Advisers Act and some state and
local pay-to-play laws outline a person can not make a contribution indirectly that is
prohibited if made directly. In other words, employees can not circumvent pay-to-play laws
by directing a family member, friend or anyone else to make a political contribution for them.

¹Government official is any individual that is elected, appointed or hired by a governmental or quasi-

governmental entity.


A.	Campaign Contributions

1.	Covered Associates per SEC Pay-to-Play

The SEC pay-to-play contribution restrictions specifically apply to employees of
an investment adviser that are deemed to be a Covered Associate. Covered
Associate is defined as executive officers and employees who solicit²government
entities for the investment adviser, along with those who directly or indirectly
supervise such employees.

Covered Associates will be notified by Compliance of their status as a Covered
Associate. Compliance will maintain a list of the Covered Associates as required,
coordinate with HR to have Covered Associate job codes identified and future
applicants (external and internal) will be vetted during the hiring process.

It is important to note the two year look-back period is effective March 14, 2011
going forward. The Advisers must look-back in time to determine whether a
Covered Associate has made a triggering prohibited contribution within the
previous two years for new Covered Associates who solicit clients, and six
months for new Covered Associates who do not solicit clients. This provision
applies to all current employees who are promoted or transferred to a Covered
Associate position and external job applicants hired into Covered Associate
position.

Non-Covered Associates political contributions do not fall under the SEC pay-to-
play restrictions, however they may be subject to state and local pay-to-play laws
and client disclosure requirements.

Check Writing Guidance: It is advised if you maintain a joint checking account, to
request your name be crossed-out on any political contribution check issued that
is not from you. By crossing-out your name on the check, it will document the
political contribution is from the non-PGI employee on the joint checking account.

2.	Pre-clearance Approval and Certification Requirements

Pre-clearance and quarterly certification is required of all employees within the
SunGard PTA system.

	a. Pre-clearance

	All employees must obtain pre-clearance approval before making a personal
	political contribution³to a:

	- State and local candidate
	(Contribution made by employee’s spouse and minor children must also
	be pre-cleared for candidates in CT, IL, KY, NJ, NM, OH, and PA.)


²Solicit means with respect to investment advisory services, to communicate, directly or indirectly, for
the purposes of obtaining or retaining a client for, or referring a client to, an investment adviser.
³Contribution is anything of value given to influence an election, most commonly contributions include
deposit of money, gift, subscription, loan, advance or any payments for debts incurred in such an
election.


	-	Federal candidate currently holding a state or local office, such as a
		Governor running for U.S. Senate.
		(If the federal candidate is not a current state or local government official,
		there are no issues related to pay-to-play and pre-clearance is not
		required)

	-	Political Action Committee (PAC)
		(Please note contributions to PrinPac are exempt from pre-clearance. See
		Section V.B. for details)

	b.	How to Pre-clear

	Employees can submit a pre-clearance request in SunGard PTA by
	completing the Political Campaign Contribution Pre-clearance Form found
	under the ‘Disclosure’ tab. Employees will be required to provide the following
	information:

	-	Employee Information
	-	Name of Candidate
	-	Campaign Office Title
	-	Campaign Jurisdiction (State/County/City)
	-	Contribution Description
	-	Contribution Amount

	Upon receiving approval of your pre-clearance request thru SunGard PTA,
	you may proceed with your political contribution. Upon contribution
	completion, you will need to provide post-clearance information within the
	SunGard PTA including the date and amount of contribution.

	c.	Review of Pre-clearance

	Compliance will review all pre-clearance requests submitted subject to the
	following:

	-	SEC Pay-to-Play De Minimis Contribution Exception for
		Covered Associates: $150 or less per election per candidate
	-	State and Local Municipality Pay-to-Play Rules
	-	Current governmental client restrictions and/or reporting requirements

	d.	Certification Acknowledgement

	All employees will also be required to complete a Quarterly Political
	Contribution Certification acknowledging all personal political campaign
	contributions have been pre-cleared in accordance with this policy.

B.	Political Action Committee (PAC)

The SEC and some state and local pay-to-play laws view contributions to certain
PACs as an indirect way to circumvent the pay-to-play laws. Therefore, all
employees are required to pre-clear contributions to PACs, with the following
exemption as set forth.


	Contributions to PrinPac do not need to be pre-cleared in SunGard PTA, as
	Government Relations which administers PrinPac, maintains records of these
	contributions. Compliance will work closely with Government Relations to meet client
	reporting requests, when applicable. There is no action required of employees.

	The Principal and the Advisers encourage employees to participate in the political
	process and support PrinPac.

	C.	Third-Party Placement Agents and Solicitors

	Investment advisers and its Covered Associates are prohibited from paying a third-
	party solicitor or placement agent to solicit business for the investment adviser from
	any government entity unless such third-party solicitor or placement agent is a SEC
	registered investment adviser or a registered broker-dealer subject to pay-to-play
	restrictions. Third-party placement agents and solicitors must be pre-approved by
	Compliance prior to entering into an agreement.

In addition to the Advisers’ Political Campaign Contribution policy provided above, all
employees are also subject to the PFG Political Activity and Government Relations Policy
which can be found on Inside The Principal.

Employees maintaining dual roles with other PFG business units will need to follow the
employee’s primary business unit Political Contributions policy and procedures. Dual
reporting will not be required.

VI.	BUSINESS GIFTS AND ENTERTAINMENT

Employees of the Advisers are subject to the PFG Travel and Entertainment Policy and the
PFG Business Gift and Entertainment Policy, found at
http://inside.principal.com/gfr/brc/busprac/statement/gifts.shtm

Access Persons must report the following through the PFG Business Gift and Entertainment
Reporting Form:

•	Business Gifts given or received greater than US$100 and may not exceed US$500
	per individual recipient per year.
•	Business Entertainment received or hosted greater than US$500 per person.
•	If your business department has implemented more stringent requirements than
	those stated in the corporate Policy, then the stricter standard applies.

For requests that require pre-approval by your Approving Officer and Chief Compliance
Officer, please direct those requests to the Advisers’ Compliance Department at
DLGAMCODEOFETHICS@exchange.principal.com. Your supervisor would be your first
point of contact prior to submitting a pre-approval request to Advisers’ Compliance
Department.

VII.	BRIBERY AND CORRUPTION POLICY

Employees of the Advisers are subject to the PFG Bribery and Corruption Policy within the
Corporate Code of Business Conduct & Ethics compliance program, found at
http://inside.principal.com/gfr/brc/toolkit/briberycorruptionpolicy.pdf.


The Advisers will not seek to influence others, either directly or indirectly, by paying or
receiving bribes or kickbacks, or by any other means that is unethical or that will harm our
reputation for honesty and integrity. Such behavior is unacceptable in all global locations in
which we conduct business, whether we are dealing with public officials, other corporations,
or private individuals. These practices are not only against our company values; they are
illegal and can expose both the employee and company to fines and other penalties,
including imprisonment.

The Advisers will not tolerate employees or representatives who achieve results at the cost
of violating the law or acting dishonestly. Employees and representatives of the Advisers are
expected to decline any opportunity which would place our ethical principles and reputation
at risk.

If you have any questions concerning the PFG Bribery and Corruption Policy, please contact
Compliance.

VIII.	SERVICE AS A DIRECTOR AND OTHER OUTSIDE BUSINESS INTERESTS

A.	Service as a Director

Access Persons are prohibited from serving, unless prior approval is granted, on the
board of directors of a publicly traded company where they will gain financial information
or participate in the investment decisions of the organization.

Authorization is based on a determination that board service would be consistent with the
interests of PFG and its clients.

Authorization needs to be obtained from the Chief Compliance Officer (or their designee).
See Schedule B – Outside Business Activities and Service as a Director Approval
Request Form.

B.	Outside Business Activities

Access Persons must not undertake other business activities outside of the Advisers
which may cause, or appear to cause, conflicts of interest. Access Persons must request
approval from the Compliance Department for all outside business activities where
Access Persons either have a controlling or influencing position, or receive monetary
compensation for their involvement in that business. Any outside employment that
potentially conflicts with the best interests of the Advisers or PFG needs to be submitted
for review and approval by your leader, the Advisers’ Compliance Department and the
PFG Conflicts Committee. It may determine that such involvement in additional business
is an actual or perceived conflict of interest with an Access Person’s current position. In
this situation, actions will need to be taken to rectify the conflict. See Schedule B –
Outside Business Activities and Service as a Director Approval Request Form.

Note the following: Access Persons that are members of PFG senior management team
reporting outside business activities through PFG Compliance are exempt from duplicate
reporting to the Advisers.

IX.	ADMINISTRATION AND SANCTIONS


The Chief Compliance Officer (or their designee) shall have the authority to interpret the
Code and grant exceptions to the Code when appropriate, such as a hardship or exigent
circumstances that warrant an exception. However, exceptions will be granted only on a rare
occasion. When exceptions are granted the Chief Compliance Officer (or their designee)
shall make a record and explain in writing the reasons and parameters of such exceptions.

The Chief Compliance Officer (or their designee) shall maintain a system for the regular
review of all reports of personal securities transactions and holdings filed under this Code.

Upon discovering a violation of this Code, the Chief Compliance Officer of the Advisers shall
impose such sanctions as determined appropriate. Sanctions may include a verbal warning
notification, letter of warning, suspension of personal Securities transactions, and other
sanctions up to and including suspension or termination of employment.

Annually, those individuals charged with the responsibility for monitoring compliance with this
Code shall prepare a written report to the Board of Directors of the Advisers that, at a
minimum, will include:

•	A certification that the Advisers has adopted procedures reasonably necessary to
	prevent Access Persons from violating the Code;

•	Identification of material violations and sanctions imposed in response to those
	violations during the past year;

•	A description of issues that arose during the previous year under the Code; and

•	Recommendations, if any, as to changes in existing restrictions or procedures based
	upon experience with this Code, evolving industry practices and changes and
	developments in applicable laws or regulations.


APPENDIX A

Personal Account Dealing Requirements Relating to Spread Betting

All staff is subject to the Principal Global Investors LLC and Principal Real Estate Investors LLC
Code of Ethics (“the Code”). The Code outlines procedures which apply to personal account
dealing.

Spread Betting is a speculative transaction that involves taking a bet on the price movement of a
security, index or other financial product via a spread betting company. For the purposes of the
Code spread betting on non-financial products, such as sporting events, is not covered.

As such spread betting is covered by the Code and no exceptions, variations or exemptions may be
made to the procedures set out in the Code. In addition to the Code there are some additional
requirements that apply to spread betting. The following applies to spread betting undertaken by an
Access Person.

1.	Pre-clearance approval of such trades is required. This should be recorded in SunGard PTA
	in accordance with the usual personal trading rules.

2.	Spread betting may not be used to circumnavigate the Personal Securities Transactions
	Rules, for example the prohibition to short sell any security on the Master Security List.

3.	The 30-calendar day minimum holding period rule does apply to spread betting.

4.	No position may be undertaken if the expiration date is less than 30-calendar days from the
	date of purchase.

5.	In order to avoid the potential of unlimited losses, each position must be set up with a “stop
	loss” instruction at the outset, or an account with a finite cash amount where, should the
	debts payable equal the balance of the account, all positions will be closed by the spread
	betting company immediately.

6.	The seven-day blackout period for portfolio managers and investment personnel authorized
	to trade does apply. This has the effect that a portfolio manager/investment personnel
	authorized to trade on a Fund/managed account may not undertake a transaction based on a
	security/financial product seven calendar days before and after a client account that he/she
	manages, advises or executes trades, trades in that security.

7.	A portfolio manager, analyst or trader who is undertaking a transaction in a security or
	financial product that is also a personal holding of the portfolio manager, analyst or trader in
	a Covered Account shall disclose such holding to his/her supervisor and the Compliance
	Department before making such investment for the Fund/managed account. A portfolio
	manager’s, analyst’s or trader’s holdings, however, shall have no affect on the
	Fund/managed account’s ability to trade. Any purchase or sale for the portfolio must then be
	reviewed and approved by a portfolio manager, analyst or trader who does not have a
	personal interest in the security or issuer and such review must be documented in writing
	and maintained.

8.	Establishing Positions Counter to Fund/Account Positions - No portfolio manager, analyst or
	trader may establish a position in his/her personal account in a security or financial product if
	the Fund/managed account for which he/she has investment authority maintains a contrary
	position.


PRINCIPAL REAL ESTATE INVESTORS, LLC (“PrinREI”)
Schedule A
U. S. REAL ESTATE INVESTMENT PROPERTY APPROVAL REQUEST FORM

Name ____________________________________________
Office Phone # ______________________________________
E-Mail _________________________________________________
Department/Job Title ______________________________________
___________________________________________________________________________________________

Purchase or Sale __________________________________________

U.S. Property Address _____________________________________


Property Type (residential, commercial, farm, etc.) _________________________________________

*Note the following property types are exempt from reporting:
•	Single Family Residential property
•	Vacation Residential property
•	Multi-Family Residential Complex property with less than 20 units
	(Examples: apartments, condos)
•	Farmland property zoned and operated as agricultural that is not adjacent to properties owned, developed
	or considered to be developed by PrinREI

Intent of Purchase (development, commercial rental, etc.) ________________________________

Planned Closing ________________________

Planned Holding Period (if purchasing) ______________________

Did the purchase opportunity arise due to PrinREI’s advisory activities on behalf of clients? ___________________

Did the purchase opportunity arise due to PrinREI’s relationship with service providers? _______________________

Are any service providers that are commonly used by PrinREI involved with this transaction? _____________________

If Yes to the above 3 questions, please describe ____________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________


Note: You must also file an Outside Business Activities Form in advance with your local Compliance Department if
you intend to act as an officer, director or hold a management position in any business or entity other than
PGI/PrinREI or any of its affiliates.

By signing below, I certify that I understand that approval, if granted, is based upon the completeness and accuracy of
the information provided herein and I agree to observe conditions imposed upon such approval.


I represent that (i) I have read and understand the PGI/PrinREI Code of Ethics (the “Code”) and recognize that I am
subject thereto; (ii) the above transaction is in compliance with the Code; (iii) to the best of my knowledge, the above
proposed transaction does not represent a conflict of interest, or the appearance of a conflict of interest, with any
PGI/PrinREI Advised Fund or Managed Account; (iv) and I have no knowledge of any pending client transactions in
this property. Furthermore, I acknowledge that no action should be taken by me to effect the transaction listed above
until I have received formal approval. I understand and acknowledge that this real estate transaction is in no way
sponsored by PGI/PrinREI or any of its affiliates and shall give rise to no liability on the part of PGI/PrinREI or any of
its affiliates whatsoever, whether by way of indemnification, insurance or otherwise.


________________________	__________________________			__________________
Employee Signature	Employee – Print Name			Date


________________________	_________________________			__________________
PrinREI Investment Committee	PrinREI Supervisor – Print Name			Date
Signature


Date Received by the Compliance Department ____________________

Chief Compliance Officer (or Designee)		¨ Approved		¨ Not Approved


_________________________________________			___________________________________
Print Name			Title


_______________________________________			__________________________________
Signature			Date


PRINCIPAL GLOBAL INVESTORS, LLC (“PGI”)
PRINCIPAL REAL ESTATE INVESTORS, LLC (“PrinREI”)
Schedule B

OUTSIDE BUSINESS ACTIVITIES AND SERVICE AS DIRECTOR/OFFICER
APPROVAL REQUEST FORM

Name: __________________________________________
Office Phone: ____________________________________
E-Mail: ________________________________________
Department/Job Title: _____________________________

I. Initial Disclosure of Outside Business Activities:

List below all outside business activities¹ you are involved in
Company Name		Type of Business	Title/Position Held	Date You First Became
				Involved With Activity




List any corporation of which you or a member of your immediate family directly or indirectly own, control, or hold the
power to vote 5% or more of the outstanding voting securities. Please include the name of the organization, the date you first
became involved with the organization, the nature of your involvement with the organization, and any other supporting
documentation that may be deemed relevant.
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________

List any joint ventures in which you participate outside your employment with PGI/PrinREI.
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________

List any trustee or executor positions you hold other than those pertaining to your immediate family.
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________

II. Pre-Clearance of serving as an Officer/Director and/or Outside Business Activities: Complete this section for each
Officer/Director and/or outside business activity listed above or for any outside business activity you plan to engage in. Please note that
all outside business activities must be pre-cleared through the completion and approval of this form, including any outside employment.
Retain a copy of the completed form for your records.

1.	Do you currently serve, or do you plan to serve, as an officer, director/trustee, partner, or employee of any entity other than
	PGI/PrinREI?	¨ Yes	¨ No
	· If you plan to serve, or currently serve, as a director/trustee, is the company publicly or privately held?
		¨ Publicly	¨ Privately

2.	Do you, or a member of your immediate family, own, or plan to own, directly or indirectly, 5% or more of the outstanding
	voting securities of any entity? ¨ Yes		¨ No



¹ “Outside business activities” are described in the Code of Ethics and generally refer to your associations with any entities other than PGI/PrinREI or any
of its affiliates.


3. Please provide the following information with respect to your Officer/Director and/or outside business activity or planned
outside business activity:

·	Name of outside entity:_________________________________________________________________________

	Address: _________________________________________________________________________

·	Country or state of formation____________________________________________________________________

	Is the company publicly or privately held?		¨ Publicly		¨ Privately

·	Type of business:_____________________________________________________________________________

·	Title or position:
	¨ Director/Trustee	¨ Officer	¨ Shareholder
	o Partner	¨ Employee	¨ Other______________________________________________
·	Amount of compensation from the outside business activity, if any: $___________________________________
	Frequency of compensation from outside business activity: ¨ Weekly					¨ Bi-Weekly
				¨ Monthly		¨ Annually

·	Amount and percentage of any stock ownership, partnership or other financial interest in this entity:
	Number of shares or units:_______________________________
	Cost per share or unit:___________________________________
	Percentage of total shares or units:______________________

·	Description of your activities, duties, and responsibilities with regard to this
	entity:______________________________________________________________________________________

·	Date of first involvement:_______________________________________________________________________

·	Approximate amount of time spent or planned to be spent on outside business activity (hours/week) ______________

·	Approximate amount of time spent or planned to be spent on outside business activity during PGI/PrinREI normal
	office hours
	(hours/week) ___________________________

·	Describe any relationship or connection or any kind between the outside entity and PGI/PrinREI:
	___________________________________________________________________________________
	__________________________________________________________________________________

·	Did PGI/PrinREI request that you accept this position with the outside entity?					¨ Yes ¨ No

By signing below, I certify that my responses to this Officer/Director and/or Outside Business Activities Form are complete, true
and accurate to the best of my knowledge. I will report any changes or corrections to this information promptly, in writing, to the
Compliance Department and will obtain prior written acknowledgement or approval as required by the Compliance Department
before any additional involvement such as participation in additional sales, holdings, compensation or participation in the
company’s management or before engaging in any future outside business activities, including any outside employment. I
hereby represent that this proposed outside business activity does not conflict with the interests of PGI/PrinREI. I hereby
confirm that the outside business activity described in this questionnaire is unrelated to and beyond the scope of my employment
by PGI/PrinREI. Notwithstanding the immediately preceding sentence, I understand that regulations and PGI/PrinREI policy
require that I obtain consent to engage in any outside business activity, and I acknowledge that such consent, if granted, is
revocable at any time, in PGI/PrinREI’s sole discretion and is subject to my understanding and acknowledgement that such
outside business activity is in no way sponsored by PGI/PrinREI and shall give rise to no liability on the part of PGI/PrinREI
whatsoever, whether by way of indemnification, insurance or otherwise.

Employee Signature:______________________________________________________________ Date:___________________

Employee’s Immediate Supervisor’s Signature__________________________________________Date:____________________

Date Received by the Compliance Department

Chief Compliance Officer (or Designee)		¨ Approved			¨ Not Approved

Name:______________________________________________				Title:__________________________________________

Signature____________________________________________				Date:__________________________________________


PRINCIPAL GLOBAL INVESTORS, LLC (“PGI”)
PRINCIPAL REAL ESTATE INVESTORS, LLC (“PrinREI”)
Schedule C

PRIVATE PLACEMENT APPROVAL REQUEST FORM
(Attach a copy of the private placement memorandum, offering memorandum or any other relevant documents)
Name: _____________________________________________
Office Phone #: _________________________________
E-Mail:	_____________________________________
Department/Job Title: _____________________________

1.	Name of the sponsor’s corporation, partnership or other entity:
	______________________________________________________________________________________
	Name of the private placement:_________________________________________________________________________________________

2.	Is the sponsor’s corporation, partnership or other entity:	¨ Public	¨ Private

3.	Type of security or fund:_______________________________________________________________________________________________

4.	Nature of participation (e.g., stockholder, selling agent, general partner, limited partner). Indicate all applicable:
	__________________________________________________________________________________________________

5.	Describe your relationship and/or work relationship to the other directors of the partnership or entity:_______________________
	____________________________________________________________________________________________________

6.	Have you received or will you receive “selling compensation”¹ in connection with the transaction? ¨ Yes ¨ No
	If yes, describe nature of compensation:__________________________________________________________________________________
	Amount of compensation:_______________________________________________________________________________________________

7.	Planned date of transaction:_____________________________________________________________________________________________

8.	Size of offering (if a fund, size of fund):__________________________________________________________________________________

9.	Size of your participation (number of units/shares and total dollar amount):___________________________________________________

10.	Your participation as a percentage of total shares or units outstanding:_______________________________________________________

11.	Does/Will the investment carry limited or unlimited liability?	¨ Limited	¨ Unlimited
	Will the investment require any use of PGI/PrinREI or any of its affiliates’ premises, facilities or materials? o Yes			o No
	If “yes”, please describe:________________________________________________________________________________________________

12.	Have you or do you intent to recommend, refer or solicit others in any way in connection with this investment? o Yes o No

13.	Is PGI/PrinREI or any of its affiliates involved? ¨Yes ¨ No
	If “Yes”, please describe:_______________________________________________________________________________________________

14.	Describe the business to be conducted by the issuer of the private placement:

15.	If the private placement is a fund, describe its investment objectives (e.g. value, growth, core or specialty):

16.	Has this private placement been made available to any PGI/PrinREI Advised Fund or any Managed Account where either you or
	the person you report to exercises investment discretion? ¨ Yes ¨ No
	If “No”, state why:_____________________________________________________________________________________________________
	If “Yes”, please describe which fund or managed account:__________________________________________________________________

17.	Do you participate or do you plan to participate in any investment decisions for the private placement? o Yes o No
	If “Yes”, please describe:_______________________________________________________________________________________________

¹ “Selling Compensation” means any compensation paid directly or indirectly from whatever source in connection with or as a result of the purchase or sale of a security, including,
through not limited to, commissions, finder’s fees, securities or rights to acquire securities, rights to participate in profits, tax benefits, or dissolution proceeds, as a general partner or
other wise, or expense reimbursements.


18.	Do you participate or do you plan to participate in the management of the sponsor? ¨ Yes		¨ No
	If “Yes”, state title ad give description of duties:___________________________________________________________________________

19.	Describe how you became aware of this private placement:_________________________________________________________________

20.	To the best of your knowledge, will this private placement result in an initial public offering within the next 12 or 18 months?
		¨Yes	¨ No


Note:	You must also file an Outside Business Activities Form in advance with your local Compliance Department if you intend to act as an
	officer, director or hold a management position in any business or entity other than PGI/PrinREI or any of its affiliates.

	I understand that approval, if granted, is based upon the completeness and accuracy of the information provided herein and I agree to
	observe any conditions imposed upon such approval. I will notify the Compliance Department in writing if any aspect of the private
	placement is proposed to be changed (e.g., investment focus of fund, compensation, involvement in organization’s management) and I
	hereby acknowledge that such changes may require further approvals or disinvestment by me.

	I represent that (i) I have read and understand the PGI/PrinREI Code of Ethics (the “Code”) and recognize that I am subject thereto; (ii)
	the above trade is in compliance with the Code; (iii) to the best of my knowledge, the above proposed trade does not represent a conflict
	of interest, or the appearance of a conflict of interest, with any PGI/PrinREI Advised Fund or Managed Account; (iv) I have no
	knowledge of any pending client orders in this security, nor is the above proposed trade in a related security which indirectly would
	result in a transaction in a security in which there are pending client orders; and (v) I have read and understand the private placement
	policy contained in the Code. Furthermore, I acknowledge that no action should be taken by me to effect the trade(s) listed above until I
	have received formal approval.

	By signing below, I certify that my responses to this Private Placement Approval Request Form are complete, true and accurate to the
	best of my knowledge. I hereby confirm that any private securities transaction described in this questionnaire is unrelated to and beyond
	the scope of my employment by PGI/PrinREI, or any of its affiliates. Notwithstanding the immediately preceding sentence, I
	understand that I must obtain consent to any private securities transactions, and I acknowledge that such consent, if granted, is revocable
	at any time and is subject to my understanding and acknowledgement that such private securities transaction is in no way sponsored by
	PGI/PrinREI or any of its affiliates and shall give rise to no liability on the part of PGI/PrinREI or any of its affiliates whatsoever,
	whether by way of indemnification, insurance or otherwise.




	_________________________________________	___________________________	_________________
	Employee Signature	Employee-Print Name	Date

	________________________________________	___________________________	________________
	Employee’s Supervisor Signature	Employee’s Supervisor-Print Name	Date


	Date Received by the Compliance Department _____________________________________


	Chief Compliance Officer (or Designee) ¨ Approved	¨ Not Approved


Name:________________________________________________________ Title:__________________________________________



Signature_____________________________________________________ Date:_________________________________________


IV.	Reporting Requirements		14
	A.	Initial Holdings Report	14
	B.	Quarterly Holdings Report	14
	C.	Annual Holdings Report	14
	D.	Initial and Annual Certification of Compliance	15
	E.	Broker Account Reporting	15

V.	Political Campaign Contributions		16

VI.	Business Gifts and Entertainment		19

VII.	Bribery and Corruption Policy		19

VIII.	Service as a Director and Other Outside Business Interests		20
	A.	Service as a Director	20
	B.	Outside Business Activities	20

IX.	Administration and Sanctions		20

Appendix A			22

Forms
	Schedule A		23
	Schedule B		25
	Schedule C		27