Post-Effective Amendment to Designate a New Effective Date
Filing Table of Contents
Document/Exhibit Description Pages Size
1: 485BXT Post-Effective Amendment 280 1.41M
2: EX-99.C HOLDERS RTS Amended and Restated Establishment and 6 25K
Designation of Series
3: EX-99.J OTHER OPININ Consent of Independent Registered Public 1 7K
Accounting Firm
4: EX-99.M 12B-1 PLAN Letter Agreement Regarding 12B-1 Fees 5± 31K
5: EX-99.P CODE ETH Code of Ethics - First Trust Advisors L.P., 14 38K
First Trust Portfolios L.P.
6: EX-99.P CODE ETH Funds Code of Ethics 11 32K
FIRST TRUST FUNDS
CODE OF ETHICS
I. STATEMENT OF GENERAL PRINCIPLES
This Code of Ethics is being adopted by the funds advised by First Trust
Advisors L.P. ("FTA") from time to time (each a "Fund" and collectively, the
"Funds"), in recognition of the fact that each Fund owes a duty at all times to
place the interests of its Investors first. In recognition of such duty it is
the Funds' policy that the personal securities transactions and other activities
of Fund personnel be conducted consistent with this Code of Ethics and in such a
manner as to avoid any actual or potential conflicts of interest or any abuse of
an individual's position of trust and responsibility that could occur through
such activities as "insider trading" or "frontrunning" investment company
securities trades. It is also the Funds' policy that Fund personnel should not
take inappropriate advantage of their position with respect to a Fund and that
such personnel should avoid any situation that might compromise, or call into
question, their exercise of fully independent judgment in the interest of
Investors in the Funds.
II. DEFINITIONS
For purposes of this Code of Ethics:
A. "Investor" shall mean any investor in a Fund.
B. "Access Person" shall mean (i) any trustee, officer or employee
of the Fund who, in connection with his or her regular functions or
duties, makes, participates in, or obtains information regarding, the
purchase or sale of securities for a Fund's portfolio or whose functions
relate to the making of any recommendations with respect to such purchases
or sales and (ii) any officer of FTA who (a) has access to nonpublic
information regarding the purchase or sale of securities for a Fund's
portfolio, or nonpublic information regarding the portfolio holdings of a
Fund; or (b) is involved in making securities recommendations to a Fund,
or who has access to such recommendations that are nonpublic; or (c) in
connection with his or her regular functions or duties, makes,
participates in, or obtains information regarding, the purchase or sale of
securities for a Fund's portfolio or whose functions relate to the making
of any such recommendations with respect to such purchases or sales.
C. "Investment Person" shall mean any officer or employee of any
Fund who in connection with his or her regular functions or duties makes,
participates in or executes decisions regarding the purchase or sale of
securities for a Fund's portfolio. Each person designated as an Investment
Person is therefore also designated as an Access Person for purposes of
this Code of Ethics.
III. PROHIBITED PRACTICES
In furtherance of the policies set forth in Section I above, the following
practices shall be prohibited:
A. No Access Person shall purchase any security during the initial
public offering of such security.
B. No Access Person shall purchase any security in a private
placement transaction unless the purchase has been approved IN WRITING AND
IN ADVANCE by the Compliance Coordinator. In considering whether to
approve any such transaction, the Compliance Coordinator shall take into
account, among other factors, whether the investment opportunity should be
reserved for a Fund and its Investors and whether the opportunity is being
offered to an individual by virtue of his or her position. Any Access
Person who has been authorized to acquire securities in a private
placement shall disclose that investment to the Compliance Coordinator
before he or she takes part in a subsequent consideration of a Fund's
investment in that issuer, and the decision to include securities of such
issuer in a Fund shall be subject to independent review by the Compliance
Coordinator to a Fund. The Compliance Coordinator shall maintain a written
record of any approvals granted under Section III A and B hereof.
C. No Access Person shall purchase or sell any security on the same
day that security is bought or sold by a Fund.
D. No Investment Person shall purchase or sell a security within
seven days before or after that security is bought or sold by a Fund if
such Investments Person knows or should know that such security is being
bought or sold by such Fund.
E. No Investment Person shall profit from the purchase and sale, or
sale and purchase, of the same (or equivalent) securities within 30
calendar days. Any profits realized on transactions prohibited by this
Section shall be disgorged.
F. No Investment Person shall serve on the Board of Directors of a
publicly traded company absent prior authorization of the Compliance
Coordinator upon a determination that board service would be consistent
with the interests of a Fund and its Investors and the establishment of
appropriate "Chinese wall" procedures by the Compliance Coordinator.
G. Any provision of this Code of Ethics prohibiting any transaction
by an Access Person or Investment Person shall prohibit any transaction in
which such person has, obtains or disposes of any beneficial ownership
interest.
H. No Access Person or Investment Person who has had two violations
of this Code of Ethics during the prior 12 month period shall purchase or
sell any security unless such purchase or sale has been approved in
advance by the Compliance Coordinator.
I. Except with respect to private placement transactions set forth
in Section III.B. above, no Access Person or Investment Person shall
purchase or sell any security of an issuer with a market capitalization of
less than $2 billion unless the security is a Fund as defined in Section
I. above or a unit investment trust sponsored by First Trust Portfolios
L.P.
IV. COMPLIANCE PROCEDURES AND REPORTING REQUIREMENTS
In order to effectuate and monitor the foregoing policies and
prohibitions, all Access Persons and Investment Persons shall be required to
comply with the following procedures:
A. The securities trading personnel of the Funds shall provide the
Compliance Coordinator with a daily summary of all executed orders entered
by, on behalf of, or with respect to the Funds.
B. Each Access Person shall direct any brokers, dealers or banks at
which he or she maintains securities accounts to provide on a timely basis
(within 30 days of each month end or calendar quarter, as applicable)
duplicate copies of confirmations of all personal securities transactions
and periodic statements for all securities accounts to the Compliance
Coordinator. The Compliance Coordinator shall date stamp all duplicate
copies of personal securities transactions and account statements upon
receipt.
C. Upon commencement of employment with a Fund or upon becoming an
officer of a Fund, each Access Person shall disclose all personal
securities holdings to the Compliance Coordinator both within 10 days
after such person becomes an Access Person by and within 30 days of the
end of each calendar year by submitting the form attached to this Code of
Ethics as Exhibit A, and the information provided must be current as of a
date no more than 45 days prior to the date such person becomes an Access
Person.
D. Within 30 days following the end of each calendar year, each
Access Person shall certify to the Funds that he or she has received, read
and understands this Code of Ethics and any amendments thereto and
recognizes that he or she is subject to it and that he or she has complied
with the requirements of this Code of Ethics by submitting the form
attached hereto as Exhibit B.
E. Any provision of this Code of Ethics requiring an Access Person
or Investment Person to report securities transactions or securities
positions to the Funds shall require the reporting of any transaction or
position, in which such person has, acquires or disposes of any beneficial
ownership interest.
F. The requirements of Section IV.B through IV.E shall be deemed to
be complied with by any Access Person or Investment Person who complies
with substantially similar requirements contained in the FTA and First
Trust Portfolios L.P. Code of Ethics.
G. The requirements of Section III.A., Section III.B., Section
III.C., Section III.G., Section III.H., Section III.I. and Sections IV.B.
through IV.E. shall not apply to any of the Independent Trustees of the
Funds; provided, however, that if the Independent Trustee knew or, in the
ordinary course of fulfilling his or her official duties as an Independent
Trustee, should have known that during the 15-day period immediately
before or after the Independent Trustee's transaction in a security, a
Fund purchased or sold the security, or a Fund or its investment adviser
considered purchasing or selling the security, the Independent Trustee
shall submit a quarterly transaction report in accordance with Rule 17j-1
under the Investment Company Act of 1940, as amended in the form of
Exhibit D.
V. PRE-CLEARANCE REQUIREMENTS
A. An Access Person may not purchase or sell, directly or
indirectly, any security in which the Access Person has (or after such
transaction would have) any beneficial ownership interest unless the
Access Person obtains prior approval for the transaction from the
Compliance Coordinator. Pre-clearance requests must be made on the date of
the contemplated transaction, through the use of the pre-trade
authorization function contained within FTA's automated pre-clearance
system. Pre-clearance requests will be reviewed to determine whether the
proposed transaction complies with this Code of Ethics, whether the
security is restricted for employees and whether the proposed transaction
raises any potential conflicts of interest or other issues. The Compliance
Coordinator will communicate to the requesting Access Person its approval
or denial of the proposed transaction via the automated pre-clearance
system application or via e-mail. Any approval will remain in effect only
until the end of the trading day on which the approval was granted. Access
Persons must wait for approval before placing the order with their broker.
B. The Compliance Coordinator will maintain an electronic log of all
pre-clearance requests and will record the approval or denial of each
request contained in the log.
C. The requirements of Section V.A. shall be deemed to be complied
with by any Access Person who complies with substantially similar
requirements contained in the FTA and First Trust Portfolios L.P. Code of
Ethics.
D. The requirements of Section V. shall not apply to any of the
Independent Trustees of the Funds.
VI. APPROVED BROKER LIST
A. With respect to all personal securities transactions, each Access
Person shall maintain an account only with a broker, dealer or bank that
is on the Funds' approved broker list attached as Exhibit C hereto (the
"Approved Broker List"). The Approved Broker List shall be maintained by
the Compliance Coordinator and may be amended at any time at the
discretion of the Compliance Coordinator.
B. The requirements of Section VI.A. shall be deemed to be complied
with by any Access Person who complies with substantially similar
requirements contained in the FTA and First Trust Portfolios L.P. Code of
Ethics.
C. The requirements of Section VI. shall not apply to any of the
Independent Trustees of the Funds.
VII. EXEMPTIONS
1. The following shall be exempted from the Prohibited Practices of
Section III.C., III.D. and III.H. and the Compliance Procedures and Reporting
Requirements set forth in Section IV; provided, however, that transactions
included in Section VII.A.5 must be included in the initial and annual holdings
reports submitted pursuant to Section IV.C.; and provided further that the names
of any and all brokers, dealers or banks with which an Access Person maintains
accounts in which ANY SECURITIES ARE HELD for the Access Person's direct or
indirect benefit must be disclosed in the initial and annual holdings reports
submitted pursuant to Section IV.C.:
A. Direct obligations of the Government of the United States.
B. Bankers' acceptances, bank certificates of deposit, commercial
paper and high quality short-term debt instruments, including repurchase
agreements.
C. Shares issued by money market funds.
D. Shares issued by open-end investment companies other than the
Funds and exchange-traded funds ("ETFs").
E. Transactions effected pursuant to an automatic investment plan,
including dividend reinvestment plans.
2. The following shall be exempted from the Prohibited Practices of
Section III.C., III.D. and III.H., BUT NOT FROM THE COMPLIANCE PROCEDURES AND
REPORTING REQUIREMENTS SET FORTH IN SECTION IV. ABOVE:
A. The purchase or sale of shares of issuers whose shares are traded
on a national or foreign securities exchange and which have a market
capitalization of at least $2 billion at the time of the transaction.
B. With respect to the purchase or sale of shares of issuers who
have a market capitalization of less than $2 billion, the purchase or sale
of shares in a single round-lot transaction of 100 shares, or odd-lot
transactions of less than 100 shares, when the aggregate number of shares
of such securities purchased or sold on a given day does not exceed 100
shares.
C. Purchases or sales of a security on behalf of an Investment
Person or an Access Person within a discretionary account when ALL
investment decisions are made by a person or entity who is UNRELATED to
the Investment Person or Access Person and such discretionary account has
been approved in advance by the Funds' Compliance Coordinator. A copy of
the executed investment management agreement must also be provided to the
Funds' Compliance Coordinator. If such discretionary account is not
approved by the Funds' Compliance Coordinator the Investment Person or
Access Person, as the case may be, is prohibited from maintaining the
discretionary account regardless of whether the Investment Person or
Access Person is seeking exemption from the Prohibited Practices of
Section III.C. and III.D.
D. Purchases or sales of shares of ETFs.
E. Unit investment trusts.
F. Sales of shares of distressed issuers (i.e., imminent bankruptcy)
whose shares are traded on a national or foreign securities exchange and
which had a market capitalization of at least $2 billion at the time of
the acquisition so long as such transaction is approved in advance by the
Compliance Coordinator. Such approval may be withheld at the discretion of
the Compliance Coordinator.
3. The following shall be exempted from the Pre-Clearance Requirements of
Section V.:
A. Direct obligations of the Government of the United States.
B. Bankers' acceptances, bank certificates of deposit, commercial
paper and high quality short-term debt instruments, including repurchase
agreements.
C. Shares issued by money market funds.
D. Shares issued by open-end investment companies other than the
Funds and ETFs.
E. Unit investment trusts.
F. Transactions effected pursuant to an automatic investment plan,
including dividend reinvestment plans.
G. Purchases or sales of a security on behalf of an Investment
Person or an Access Person within a discretionary account when ALL
investment decisions are made by a person or entity who is UNRELATED to
the Investment Person or Access Person and such discretionary account has
been approved in advance by the Funds' Compliance Coordinator. A copy of
the executed investment management agreement must also be provided to the
Funds' Compliance Coordinator. If such discretionary account is not
approved by the Funds' Compliance Coordinator the Investment Person or
Access Person, as the case may be, is prohibited from maintaining the
discretionary account regardless of whether the Investment Person or
Access Person is seeking exemption from the Prohibited Practices of
Section V.
4. The following shall be exempted from the Approved Broker List
Requirements of Section VI.:
A. Discretionary accounts where ALL investment decisions are made by a
person or entity who is UNRELATED to the Investment Person or Access
Person and such discretionary account has been approved in advance by the
Funds' Compliance Coordinator. A copy of the executed investment
management agreement must also be provided to the Funds' Compliance
Coordinator. If such discretionary account is not approved by the Funds'
Compliance Coordinator the Investment Person or Access Person, as the case
may be, is prohibited from maintaining the discretionary account.
B. Brokerage accounts where the only securities contained in such
account are (i) direct obligations of the Government of the United States,
(ii) bankers' acceptances, bank certificates of deposit, commercial paper
and high quality short-term debt instruments, including repurchase
agreements, (iii) shares issued by money market funds, and/or (iv) shares
issued by open-end investment companies but not the Funds and ETFs.
C. Brokerage accounts required by law or company policy to be
maintained at a broker, dealer or bank not contained on the Approved
Broker List; provided, however, all discretionary accounts must comply
with the provisions contained in Section VII.D.1.
VI. SANCTIONS
Upon discovery of a violation of this Code of Ethics, including either
violations of the enumerated provisions or the general principles provided, the
Funds may impose such sanctions as deemed appropriate, including, inter alia, a
fine, letter of censure or suspension or termination of the employment of the
violator. In addition, any profits realized on transactions prohibited by this
Code of Ethics shall be disgorged.
Amended: June 13, 2005
Amended: December 31, 2008
Amended: March 22, 2010
Amended: September 16, 2013
Amended: October 30, 2013
EXHIBIT A
CODE OF ETHICS
ACCESS/INVESTMENT PERSON
SECURITIES HOLDINGS REPORT
Name of Access/Investment Person: ______________________________________________
Date: _______________
[_] I hereby certify that as of _______________, I had a beneficial ownership
interest in no securities other than those set forth below.
ISSUER # OF SHARES/PRINCIPAL AMOUNT MARKET VALUE
OR
[_] I hereby certify that as of _______________, I had a beneficial ownership
interest in no securities other than those set forth on the attached
brokerage account statements.
OR
[_] I hereby certify that as of _______________, I had a beneficial interest
in no securities.
As of ______________, I maintained accounts where securities are held for my
direct or indirect benefit at the following brokers, dealers or banks:
--------------------------------------------------------------------------------
--------------------------------------------------------------------------------
--------------------------------------------------------------------------------
--------------------------------------------------------------------------------
-----------------------------
Signature
EXHIBIT B
ACCESS/INVESTMENT PERSON
CODE OF ETHICS CERTIFICATION
I, ____________________, hereby certify that I have received, read, and
understand the Code of Ethics for the Funds dated October 30, 2013. I recognized
that I am subject to this Code of Ethics. Furthermore, I certify that (i) I have
complied during the preceding year with the provisions of the Code of Ethics in
effect during such time period, (ii) I have disclosed or reported all personal
securities transactions required to be disclosed or reported pursuant to the
requirements of the Code of Ethics in effect during such time period, (iii) I
will comply with the provisions of the Code of Ethics dated October 30, 2013, as
may be amended from time to time, during the next twelve months and (iv) I will
disclose or report all personal securities transactions required to be disclosed
or reported pursuant to the requirements of the Code of Ethics dated October 30,
2013, as may be amended from time to time, during the next twelve months.
Date: _______________
---------------------------------------
Signature
EXHIBIT C
APPROVED BROKER LIST
TO BE MAINTAINED BY THE COMPLIANCE COORDINATOR
| EX-99.p CODE ETH | Last Page of 11 | TOC | 1st | Previous | Next | ↓Bottom | Just 11th |
|---|
EXHIBIT D
QUARTERLY TRANSACTION REPORT
Name: __________________________________________________________________________
Date: _______________
[_] I hereby certify that during the calendar quarter ended _________________,
I had a beneficial ownership interest in the following securities
transactions:
TYPE OF TYPE OF # OF SHARES/
TRANSACTION SECURITY ISSUER PRINCIPAL AMOUNT $ AMOUNT
OR
[_] I hereby certify that during the calendar quarter ended _________________,
I had a beneficial ownership interest in no securities transactions other
than those set forth on the attached brokerage account confirmations.
OR
[_] I hereby certify that during the calendar quarter ended _________________,
I had a beneficial ownership interest in no securities transactions.
---------------------------------------
Signature
Dates Referenced Herein and Documents Incorporated by Reference
23 Subsequent Filings that Reference this Filing
↑Top
Filing Submission 0001445546-14-002358 – Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)
Copyright © 2024 Fran Finnegan & Company LLC – All Rights Reserved.
About — Privacy — Redactions — Help —
Sat., May 4, 4:46:55.4pm ET 
