Code of Ethics
The Code of Ethics for Evergreen Investment Management Company, LLC (EIMCO) establishes three categories of personnel (Investment Persons, Access Persons and Employees) that are subject to varying requirements relating to, among other things,
- the reporting of securities holdings and transactions, and
- the pre-clearance of securities transactions.
Generally, no Employee (the broadest category) may engage in any securities transactions, activity or relationship that creates or has the appearance of creating a conflict of interest (financial or other) between the Employee and the firm or a client account. Each Employee must always place the financial and business interests of the firm and client accounts before his or her own personal financial and business interests. Each Employee is prohibited from purchasing or selling any security if he or she knows such security
- is being purchased or sold for any client account or
- is being actively considered for purchase or sale by any client account.
Each Employee is also prohibited from purchasing or selling securities while in possession of "inside information."
All Access Persons (which, as a practical matter includes all Investment Persons) are required to report
- securities holdings upon becoming an Access Person and annually thereafter, and
- all securities transactions on a quarterly basis.
Access Persons are also required to pre-clear securities transactions (including investments in private offerings and initial public offerings), except for certain exempt transactions. Investment Persons also are not allowed to profit from short-term trading (any purchase and sale or sale and purchase made within 60 days) in any securities, except under very limited circumstances.
EIMCO’s Code of Ethics has also established rules relating to investments in the Evergreen mutual funds and mutual funds subadvised by EIMCO or an affiliate. Investment Persons are required to hold all such investments for 6 months. Employees who are not Investment Persons are required to hold all such investments for 90 days. All Employees are required to hold all investments in Evergreen mutual funds either directly with Evergreen Service Company, LLC (the funds’ transfer agent) or Wachovia Securities (an affiliated broker-dealer), with certain exceptions for retirement accounts.
More generally, EIMCO’s Code of Ethics requires all Employees to comply with all applicable federal securities laws and prohibits Employees from engaging in fraudulent activity relating to a client account or in any transaction that may give the appearance of impropriety. All Employees are required to promptly report any violations of the Code of Ethics of which they become aware. Possible sanctions for violations of the Code of Ethics include disgorgement of profits, fines, letters of reprimand, and suspension or termination of employment.
Please note that the foregoing description is merely a summary of EIMCO’s Code of Ethics. For further details on the policies, procedures and restrictions set forth in the Code of Ethics, including details about the firm's pre-clearance requirements, please contact EIMCO to obtain a copy of the Code of Ethics.