|
||||||||||||||||||||||||||
| SEC Info℠ | | | Home | | | Search | | | My Interests | | | Help | | | Sign In | | | Please Sign In | |||||||
|
||||||||||||||||||||||||||
As Of Filer Filing For·On·As Docs:Size Issuer Filing Agent 12/21/21 Morgan Stanley Inst’l Fund Inc. 485BPOS 12/21/21 26:5.1M Broadridge Fin’l… Inc/FA → Vitality Portfolio ⇒ Class A (MSVEX) — Class C (MSVMX) — Class I (MSVDX) — Class R6 (MSVOX) |
Document/Exhibit Description Pages Size
1: 485BPOS Ms Institutional Fund Inc-485Bpos HTML 1.21M
2: EX-99.(A)(102) Articles Supplementary to Registrants Articles HTML 84K
of Amendment and Restatement (Adding Vitality
Portfolio)
3: EX-99.(A)(103) Articles Supplementary to Registrants Articles HTML 84K
of Amendment and Restatement (Adding Class Ir
Shares to Global Focus Real Estate Portfolio)
4: EX-99.(B) Amended and Restated By-Laws HTML 63K
5: EX-99.(D)(1) Amended and Restated Investment Advisory HTML 42K
Agreement Between the Registrant and Morgan
Stanley Investment Management Inc.
6: EX-99.(G) Custodian Contract Between the Registrant and HTML 226K
State Street Bank and Trust Company
7: EX-99.(H)(2) Transfer Agency and Service Agreement With HTML 204K
Boston Financial Data Services, Inc.
8: EX-99.(I)(87) Opinion and Consent of Dechert LLP HTML 15K
9: EX-99.(I)(88) Opinion and Consent of Ballard Spahr LLP HTML 24K
10: EX-99.(M)(1) Amended and Restated Shareholder Services Plan HTML 28K
Under Rule 12B-1 for Class A Shares
11: EX-99.(M)(3) Distribution and Shareholder Services Plan Under HTML 24K
Rule 12B-1 for Class C Shares
12: EX-99.(N) Amended and Restated Multiple Class 18F-3 Plan HTML 61K
13: EX-99.(P)(2) Code of Ethics for Morgan Stanley Funds HTML 28K
19: R1 Document And Entity Information HTML 28K
20: R2 MSIF Vitality Portfolio - Classes I, A, C and IS HTML 173K
21: R3 Risk/Return Detail Data HTML 191K
24: XML IDEA XML File -- Filing Summary XML 23K
22: XML XBRL Instance -- msif-html4214_485bpos_htm XML 128K
23: EXCEL IDEA Workbook of Financial Reports XLSX 26K
15: EX-101.CAL XBRL Calculations -- stanley-20211221_cal XML 23K
16: EX-101.DEF XBRL Definitions -- stanley-20211221_def XML 243K
17: EX-101.LAB XBRL Labels -- stanley-20211221_lab XML 388K
18: EX-101.PRE XBRL Presentations -- stanley-20211221_pre XML 216K
14: EX-101.SCH XBRL Schema -- stanley-20211221 XSD 22K
25: JSON XBRL Instance as JSON Data -- MetaLinks 36± 65K
26: ZIP XBRL Zipped Folder -- 0001133228-21-006096-xbrl Zip 432K
Exhibit (p)(2)
Morgan Stanley Funds Code of Ethics
1. Introduction
This Code of Ethics (the “Code”) is adopted pursuant to Rule 17j-1 under the Investment Company Act of 1940, as amended (the “1940 Act”) and applies to the registered investment companies (each, a “Fund” and collectively, the “Funds”) advised or managed by Morgan Stanley Investment Management Inc. or any of its affiliates (“MSIM”). This Code applies to all persons who are “Access Persons” of the Funds, as that term is defined in Rule 17j-1. To the extent that any such individuals are subject to compliance with the MSIM Public Side Code of Ethics and Personal Trading Guidelines (the “MSIM Public Side Code of Ethics”), which has been adopted pursuant to Rule 17j-1, compliance by such individuals with the provisions of the MSIM Public Side Code of Ethics shall constitute compliance with this Code. The Code will be effective for a Fund upon its adoption by that Fund’s Board of Directors or Trustees.
2. Reporting Requirements
2.1 Reports of Transactions - Independent Directors/Trustees and Directors/Trustees who are not Access Persons
A director or trustee of a Fund who is not an “interested person” of the Fund within the meaning of Section 2(a)(19) of the 1940 Act (an “Independent Director/Trustee”) and a director or trustee of a Fund who is not an Access Person shall report quarterly to the MSIM Legal Department any personal transaction in a security if he or she knows or in the course of his/her duties as a Director/Trustee of the Fund should have known that (i) the Fund had purchased or sold the same security; or (ii) MSIM considered purchasing or selling the same security during the 15 day period immediately before or after the Independent Director’s/Trustee’s transaction in the same security.
2.2 Reports of Transactions, Brokerage Accounts and Holdings - Access Persons not covered by Section 2.1
No later than ten days after becoming an Access Person, new Access Persons who are not covered by Section 2.1 will be required to provide:
| • | A list of all non-exempt securities holdings, with the information set forth below under annual reporting, as of the date of becoming an Access Person; and |
| • | A list of all outside brokerage accounts, including open end investment company accounts. The information must be current as of a date not more than 30 days before the information is submitted. |
On a quarterly basis, an Access Person of a Fund who is not covered by Section 2.1 shall report:
| • | All non-exempt securities transactions; and |
| Content as-of Date: | 15-11-2021 | Printed on: | 15-11-2021 | FOR INTERNAL USE ONLY 1 |
| • | A list of brokerage accounts and open-end registered investment company accounts opened during the quarter, to the MSIM Code of Ethics Group. |
On an annual basis, an Access Person of a Fund who is not covered by Section 2.1 shall provide the MSIM Code of Ethics Group with:
| • | A list of holdings of all non-exempt securities beneficially owned by such Access Person as of March 31 the title of the security, the number of shares held, and the principal amount of the security; |
| • | The name of any broker dealer, financial institution or open-end investment company where an account was maintained by such Access Person, as of March 31; and |
| • | The date the information is submitted by the Access Person. |
An Access Person who is identified as “Investment Personnel” (as defined in Rule 17j-1) of a Fund must obtain approval from the MSIM Code of Ethics Group before directly or indirectly acquiring beneficial ownership in any securities in an initial public offering or in a limited offering.
2.3 Reports of Transactions, Brokerage Accounts and Holdings – General
Any quarterly report required above must be made within thirty days after the end of the calendar quarter in which the personal transaction occurred. The report may be made on the form provided by the MSIM Code of Ethics Group or may consist of a broker statement that provides at least the same information. In the event that the MSIM Code of Ethics Group already maintains a record of the required information, an Access Person may satisfy this requirement by (i) confirming in writing (which may include e-mail) the accuracy and completeness of the record and disclosing the beneficial ownership of securities (if any) not listed on the account statement; and (ii) recording the date of the confirmation.
The MSIM Code of Ethics Group, or the MSIM Legal Department, as applicable, will identify and advise all Access Persons of the Fund, including the Independent Directors/Trustees and the Directors/Trustees who are not Access Persons, subject to the reporting requirement above, of their reporting requirement. Each report required under this Section 2.3 will be submitted for review by the MSIM Code of Ethics Group.
3. Definitions and Exemptions
3.1 Definitions
For purposes of this Code
The term “personal transaction” means the purchase or sale, or other acquisition or disposition, of a security for the account of the individual making the transaction or for an account in which he or she has, or as a result of the transaction acquires, any direct or indirect beneficial ownership in a security.
The term “beneficial ownership” shall be interpreted with reference to the definition contained in the provisions of Section 16 of the Securities Exchange Act of 1934, as amended. Generally, under Section 16, a person is regarded as having beneficial ownership of securities held in the name of:
| Content as-of Date: | 15-11-2021 | Printed on: | 15-11-2021 | FOR INTERNAL USE ONLY 2 |
| • | The individual; or |
| • | A husband, wife or a minor child; or |
| • | A relative sharing the same household; or |
| • | Other person if the Access Person: |
| - | Obtains benefits substantially equivalent to ownership of the securities; or |
| - | Can obtain ownership of the securities immediately or at some future time. |
For further information, please refer to the definition of “Immediate Family” below.
The term “Access Person” is defined by Rule 17j-1 under the 1940 Act as (i) any director, officer, general partner or employee of a fund or of a fund’s investment adviser (or of any company in a control relationship to the fund or investment adviser) who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of Covered Securities (as defined in Rule 17j-1) by a fund, or whose functions relate to the making or any recommendations with respect to such purchases or sales; or (ii) any director, officer, or general partner of a principal underwriter who, in the ordinary course of business, makes, participates in or obtains information regarding, the purchase or sale of Covered Securities (as defined in Rule 17j-1) by the fund for which the principal underwriter acts, or whose functions or duties in the ordinary course of business relate to the making of any recommendation to the fund regarding the purchase or sale of Covered Securities.
The term “Immediate Family” includes any of the following persons sharing the same household with you (which does not include temporary house guests): an Employee’s child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, legal guardian, adoptive relative, or significant other. Or any relationship for whom the Employee contributes substantial financial support (e.g., a child in college that is claimed as a dependent on your income tax return or who receives health benefits through you) or the person is aware of a specific transaction or has direct or indirect influence or control over a transaction.
3.2 Exemptions
No report is required for a personal transaction in any of the following securities:
| • | U.S. government securities; |
| • | Bank certificates of deposit; |
| • | Bankers’ acceptances; |
| • | Commercial paper; |
| • | U.S. government agency securities; |
| • | High quality short-term instruments (including repurchase agreements); |
| • | Open-end registered investment companies (mutual funds) not advised or sub-advised by MSIM (as defined in the MSIM Public Side Code of Ethics); and |
| • | Money market funds. |
Also, no report is required with respect to any account over which the Access Person has no influence or control.
| Content as-of Date: | 15-11-2021 | Printed on: | 15-11-2021 | FOR INTERNAL USE ONLY 3 |
4. Violations of the Code
Any officer of a Fund who discovers a violation or apparent violation of this Code by an Access Person shall bring the matter to the attention of the Chief Compliance Officer of the Fund who shall then report the matter to the Board of Directors/ Trustees of the Fund. The Board shall determine whether a violation has occurred and, if it so finds, may impose such sanctions, if any, as it considers appropriate.
5. Administration of the Code
No less frequently than annually the Board of Directors or the Board of Trustees of each of the Funds shall be provided with (i) a written report that describes any new issues arising under the Code, including information on material violations of the Code or procedures and sanctions imposed; and (ii) a certification from the Fund’s Chief Compliance Officer that each Fund has adopted procedures reasonably necessary to prevent Access Persons from violating the Code.
6. Code Governance
| Effective | December 2021 |
| Risk Addressed | Failure to comply with Rule 17j-1 |
| Relevant Law and other Sources | Rule 17j-1 under the Investment Company Act of 1940, as amended |
| Owner | IM Policies and Procedures Group Head |
| Approver | MSIM Funds CCO |
| Contact Information | Compliance (Elise Clark, Stephanie DeCaro) |
| Intranet Location | https://policy.webfarm.ms.com/policies/portal/#/document-preview/1999684? sectionid=_bf9083d4-a7ff-4b8c-bd9e-fbdbae61d564 |
Approved by the Boards of the Morgan Stanley Funds on June 9-10, 2015, December 2, 2021
| Content as-of Date: | 15-11-2021 | Printed on: | 15-11-2021 | FOR INTERNAL USE ONLY 4 |
| This ‘485BPOS’ Filing | Date | Other Filings | ||
|---|---|---|---|---|
 | ||||
| Filed on / Effective on: | 12/21/21 | 497K | ||
| 12/2/21 | ||||
| List all Filings | ||||