Putnam Investment Funds, et al. · 485APOS · On 10/29/04 · EX-99.P CODE ETH

Filed On 10/29/04 4:52pm ET   ·   SEC Files 33-56339, 811-07237   ·   Accession Number 928816-4-1174

Post-Effective Amendment
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 485APOS     Putnam Investment Funds                              182±   738K 
 2: EX-99.P CODE ETH  Miscellaneous Exhibit                            5±    22K 

EX-99.P CODE ETH   ·   Miscellaneous Exhibit

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THE PUTNAM FUNDS      

Code of Ethics      

Each of The Putnam Funds (the "Funds") has determined to adopt this Code        
of Ethics with respect to certain types of personal securities                  
transactions by officers and Trustees of the Funds which might be deemed        
to create possible conflicts of interest and to establish reporting             
requirements and enforcement procedures with respect to such                    
transactions.                                                                   

I. Rules Applicable to Officers and Trustees Affiliated with Putnam             
Investments Trust or Its Subsidiaries                                           

A. Incorporation of Adviser's Code of Ethics.  The provisions of the            
Code of Ethics for employees of Putnam Investments Trust and its                
subsidiaries (the "Putnam Investments Code of Ethics"), which is                
attached as Appendix A hereto, are hereby incorporated herein as the            
Funds' Code of Ethics applicable to officers and Trustees of the Funds          
who are employees of the Funds or officers, directors or employees of           
Putnam Investments Trust or its subsidiaries.  A violation of the Putnam        
Investments Code of Ethics shall constitute a violation of the Funds'           
Code.                                                                           

B. Reports.  Officers and Trustees of each of the Funds who are made            
subject to the Putnam Investments Code of Ethics pursuant to the                
preceding paragraph shall file the reports required by the Putnam               
Investments Code of Ethics with the Code of Ethics Officer designated           
therein.  A report filed with the Code of Ethics Officer shall be deemed        
to be filed with each of the Funds of which the reporting individual is         
an officer or Trustee.                                                          

C. Review.                                                                      

(1) The Code of Ethics Officer shall compare the reported personal              
securities transactions with completed and contemplated portfolio               
transactions of each of the Funds to determine whether a violation of           
this Code may have occurred.  Before making any determination that a            
violation has been committed by any person, the Code of Ethics Officer          
shall give such person an opportunity to supply additional explanatory          
material.                                                                       

(2) If the Code of Ethics Officer determines that a violation of this           
Code has or may have occurred, he shall submit his written                      
determination, together with any additional explanatory material, to the        
Chairman of the Funds, who shall make an independent determination of           
whether a violation has occurred.                                               

D. Sanctions.  If the Chairman of the Funds finds that a violation has          
occurred, he shall report the violation and any sanction imposed under          
the Putnam Code of Ethics to the Trustees of the Funds who may impose           
such additional sanctions as they deem appropriate.                             

II. Rules Applicable to Unaffiliated Trustees                                   

A. Definitions.                                                                 

(1) "Beneficial ownership" shall be interpreted in the same manner as it        
would be in determining whether a person is subject to the provisions of        
Section 16 of the Securities Exchange Act of 1934 and the rules and             
regulations thereunder.                                                         

(2) "Control" means the power to exercise a controlling influence over          
the management or policies of a company, unless such power is solely the        
result of an official position with such company.                               

(3) "Interested Trustee" means a Trustee of a Fund who is an "interested        
person" of the Fund within the meaning of the Investment Company Act.           

(4) "Purchase or sale of a security" includes, among other things, the          
writing of an option to purchase or sell a security.                            

(5) "Security" shall have the same meaning as that set forth in Section         
2(a)(36) of the Investment Company Act (in effect, all securities)              
except that it shall not include securities issued by the Government of         
the United States or an agency thereof, bankers' acceptances, bank              
certificates of deposit, commercial paper and shares of registered              
open-end investment companies.                                                  

(6) "Unaffiliated Trustee" means a Trustee who is not made subject to           
the Putnam Investments Code of Ethics pursuant to Part I hereof.                

B. Prohibited Purchases and Sales.  No Unaffiliated Trustee of any of the       
Funds shall purchase or sell, directly or indirectly, any security in           
which he has, or by reason of such transaction acquires, any direct or          
indirect beneficial ownership and which to his actual knowledge at the          
time of such purchase or sale:                                                  

(1) is being considered for purchase or sale by the Fund;                       

(2) is being purchased or sold by the Fund; or                                  

(3) was purchased or sold by the Fund within the most recent five days          
if such person participated in the recommendation to, or the decision           
by, Putnam Investment Management to purchase or sell such security for          
the Fund.                                                                       

C. Exempted Transactions.  The prohibitions of Section II-B of this Code        
shall not apply to:                                                             

(1) purchases or sales effected in any account over which the                   
Unaffiliated Trustee has no direct or indirect influence or control;            

(2) purchases or sales which are non-volitional on the part of either           
the Unaffiliated Trustee or the Fund;                                           

(3) purchases which are part of an automatic dividend reinvestment plan;        

(4) purchases effected upon the exercise of rights issued by an issuer          
pro rata to all holders of a class of its securities, to the extent such        
rights were acquired from such issuer, and sales of such rights so              
acquired;                                                                       

(5) purchases or sales other than those exempted in (1) through (4)             
above which do not cause the Unaffiliated Trustee to gain improperly a          
personal benefit through his relationship with the Fund and are only            
remotely potentially harmful to a Fund because they would be very               
unlikely to affect a highly institutional market, and are previously            
approved by the Code of Ethics Officer under the Putnam Code of Ethics          
or the Chairman of the Funds, which approval shall be confirmed in              
writing.                                                                        

D. Reporting.                                                                   

(1) Whether or not one of the exemptions listed in Section II-C applies,        
every Unaffiliated Trustee of a Fund shall file with the Chairman of the        
Funds a report containing the information described in Section II-D(2)          
of this Code with respect to transactions in any security in which such         
Unaffiliated Trustee has, or by reason of such transaction acquires, any        
direct or indirect beneficial ownership, if such Trustee, at the time of        
that transaction, knew or, in the ordinary course of fulfilling his             
official duties as a Trustee of the Fund, should have known that, during        
the 15-day period immediately preceding or after the date of the                
transaction by the Trustee:                                                     

(a) such security was or is to be purchased or sold by the Fund or              

(b) such security was or is being considered for purchase or sale by the        
Fund;                                                                           

provided, however, that an Unaffiliated Trustee shall not be required to        
make a report with respect to transactions effected for any account over        
which such person does not have any direct or indirect influence or             
control.                                                                        

(2) Every report shall be made not later than 10 days after the end of          
the calendar quarter in which the transaction to which the report               
relates was effected, and shall contain the following information:              

(a) The date of the transaction, the title and the number of shares, and        
the principal amount of each security involved;                                 

(b) The nature of the transaction (i.e., purchase, sale or any other            
type of acquisition or disposition);                                            

(c) The price at which the transaction was effected; and                        

(d) The name of the broker, dealer or bank with or through whom the             
transaction was effected.                                                       

(3) Every report concerning a purchase or sale prohibited under Section         
II-B hereof with respect to which the reporting person relies upon one          
of the exemptions provided in Section II-C shall contain a brief                
statement of the exemption relied upon and the circumstances of the             
transaction.                                                                    

(4) Any such report may contain a statement that the report shall not be        
construed as an admission by the person making such report that he has          
any direct or indirect beneficial ownership in the security to which the        
report relates.                                                                 

(5) Notwithstanding anything to the contrary contained herein, an               
Unaffiliated Trustee who is an "interested person" of the Fund shall            
also file the reports required by Rule 17j-1(d)(1) under the Investment         
Company Act of 1940.                                                            

E. Review.                                                                      

(1) The Chairman of the Funds shall compare the reported personal               
securities transactions with completed and contemplated portfolio               
transactions of the Funds to determine whether any transaction                  
("Reviewable Transactions") listed in Section II-B (disregarding                
exemptions provided by Section II-C(1) through (5)) may have occurred.          

(2) If the Chairman determines that a Reviewable Transaction may have           
occurred, he shall then determine whether a violation of this Code may          
have occurred, taking into account all the exemptions provided under            
Section II-C.  Before making any determination that a violation has             
occurred, the Chairman shall give the person involved an opportunity to         
supply additional information regarding the transaction in question.            

F. Sanctions.  If the Chairman determines that a violation of this Code         
has occurred, he shall so advise a committee consisting of the                  
Unaffiliated Trustees, other than the person whose transaction is under         
consideration, and shall provide the committee with a report of the             
matter, including any additional information supplied by such person.           
The committee may impose such sanctions as it deems appropriate.                

III. Miscellaneous                                                              

A. Amendments to the Putnam Investments Code of Ethics.  Any amendment          
to the Putnam Investments Code of Ethics shall be deemed an amendment to        
Section I-A of this Code effective 30 days after written notice of such         
amendment shall have been received by the Chairman of the Funds, unless         
the Trustees of the Funds expressly determine that such amendment shall         
become effective at an earlier or later date or shall not be adopted.           

B. Records.  The Funds shall maintain records in the manner and to the          
extent set forth below, which records may be maintained on microfilm            
under the conditions described in Rule 31a-2(f)(1) under the Investment         
Company Act and shall be available for examination by representatives of        
the Securities and Exchange Commission.                                         

(1) A copy of this Code and any other code which is, or at any time             
within the past five years has been, in effect shall be preserved in an         
easily accessible place;                                                        

(2) A record of any violation of this Code and of any action taken as a         
result of such violation shall be preserved in an easily accessible             
place for a period of not less than five years following the end of the         
fiscal year in which the violation occurs;                                      

(3) A copy of each report made by an officer or Trustee pursuant to this        
Code shall be preserved for a period of not less than five years from           
the end of the fiscal year in which it is made, the first two years in          
an easily accessible place; and                                                 

(4) A list of all persons who are, or within the past five years have           
been, required to make reports pursuant to this Code shall be maintained        
in an easily accessible place.                                                  

To the extent any record required to be kept by this section is also            
required to be kept by Putnam Investments pursuant to the Putnam                
Investments Code of Ethics, Putnam Investments shall maintain such              
record on behalf of the Funds as well.                                          

C. Confidentiality.  All reports of securities transactions and any             
other information filed with any Fund pursuant to this Code shall be            
treated as confidential, but are subject to review as provided herein           
and by personnel of the Securities and Exchange Commission.                     

D. Interpretation of Provisions.  The Trustees may from time to time            
adopt such interpretations of this Code as they deem appropriate.               

E. Delegation by Chairman.  The Chairman of the Funds may from time to          
time delegate any or all of his responsibilities under this Code, either        
generally or as to specific instances, to such officer or Trustee of the        
Funds as he may designate.                                                      

As revised                                                                      
July 8, 2004                                                                    

Dates Referenced Herein   and   Documents Incorporated By Reference

This 485APOS Filing		Date		Other Filings
		7/8/04
Filed On / Filed As Of		10/29/04		NSAR-A, NSAR-B
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