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As Of Filer Filing For·On·As Docs:Size Issuer Filing Agent 7/30/21 Delaware Group Income Funds 485BPOS 7/30/21 24:4.7M Digital Publishi… Inc/FA → Delaware Floating Rate Fund ⇒ Class A (DDFAX) — Class C (DDFCX) — Class R (DDFFX) — Class R6 (DDFZX) — Institutional Class (DDFLX) |
Document/Exhibit Description Pages Size
1: 485BPOS Post-Effective Amendment Filed Pursuant to HTML 1.22M
Securities Act Rule 485(B)
2: EX-99.D.5 Executed Investment Advisory Expense Limitation HTML 15K
Letter (June 2021)
3: EX-99.J Consent of Independent Registered Public HTML 9K
Accounting Firm (July 2021)
4: EX-99.P.2 Code of Ethics for Macquarie Investment Management HTML 47K
Austria Kapitalanlage Ag (June 2021)
5: EX-99.P.3 Code of Ethics for Macquarie Investment Management HTML 31K
Europe Limited (March 2021)
6: EX-99.P.4 Code of Ethics for Macquarie Investment Management HTML 81K
Global Limited (February 18, 2021)
12: R1 Document and Entity Information HTML 21K
13: R2 Risk/Return Summary HTML 73K
14: R3 Risk/Return Detail Data HTML 264K
15: R4 Shareholder Fees HTML 29K
16: R5 Annual Fund Operating Expenses HTML 43K
17: R6 Expense Example HTML 11K
18: R7 Expense Example, No Redemption HTML 9K
19: R8 Annual Total Returns HTML 38K
20: R9 Average Annual Total Returns HTML 11K
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11: XML XBRL Instance -- dgif-20200731_htm XML 123K
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EX-99.p.3
SECTION 14 MIMEL EMPLOYEE INFORMATION: PERSONAL CONFLICTS OF INTEREST
Macquarie Investment Management Europe Limited
Code of Ethics
I. Persons Subject to the Code of Ethics
This Code of Ethics (the Code) has been adopted by the Directors of Macquarie Investment Management Europe Limited (MIMEL) to provide regulations and procedures consistent with the Advisers Act Rule 204A-1 and Rule 17j-1 of The Investment Company Act of 1940, as amended (the “1940 Act”), thereunder, as well as other securities law and sound business practices.
The procedures in the Code are designed to prevent Access Persons, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by any client of MIMEL, from:
| 1. | employing any device, scheme or artifice to defraud any other client of MIMEL; |
| 2. | making any untrue statement of a material fact to any other client of MIMEL or omit to state a material fact necessary in order to make the statements made to any other client of MIMEL, in light of the circumstances under which they are made, not misleading; |
| 3. | engaging in any act, practice or course of business that operates or would operate as a fraud or deceit on any other client of MIMEL; or |
| 4. | engaging in any manipulative practice with respect to any other client of MIMEL. |
An Access Person within the meaning of this Code, is a person who has been designated as such by the MIMEL CCO or his or her designee(s). Generally, an Access Person is any person defined in the Definitions section that follows as an “Access Person”.
Immediate family members sharing the same household with any MIMEL Access Person are also deemed, by law, to be Access Persons for purposes of this Code. In addition, Rule 17j-1 under the 1940 Act and Rule 204A-1 under the Investment Advisers Act of 1940, as amended, contain a presumption that, if the investment adviser’s primary business is providing investment advice to Funds or other advisory clients, then all of its directors, officers and partners are presumed to be Access Persons of any Fund advised by the Adviser.
II. Fiduciary Duties of Access Persons Under Federal Securities Laws
MIMEL Access Persons owe a fiduciary duty to MIMEL’s clients. These duties include a duty at all times to place the interests of each entity’s respective clients first. Above all, this means all MIMEL Access Persons owe an undivided duty of loyalty to MIMEL’s clients. Further, MIMEL demands the highest degree of personal and professional integrity and ethical behavior from their Access Persons.
Accordingly, all MIMEL Access Persons must conduct themselves in an ethical manner and in such a way as to avoid not only actual conflicts of interest with MIMEL’s clients the appearance of a conflict that could compromise the trust such clients have placed in MIMEL.
All Access Persons must comply fully with all applicable laws, including applicable federal securities laws.
III. Personal Trading and Reporting
Access Persons should consider trading in stocks, bonds, and closed-end mutual funds for their personal accounts a privilege while working at MIMEL.
Failure to comply with MIMEL’s pre-clearance and reporting procedures, as described below, may result in the loss of personal trading privileges and may lead to additional disciplinary action, up to and including termination of employment.
In addition, because MIMEL is a wholly-owned subsidiary of MGL, an Australian-based investment bank, MIMEL Access Persons are subject to MGL’s pre-clearance requirements. Failure to comply with MGL’s pre-clearance requirements will also result in the loss of personal trading privileges and may also lead to additional disciplinary action, up to and including termination of employment.
A. Personal Holdings Reports
Every Access Person of MIMEL must provide to the CCO:
| ● | no later than 10 (ten) calendar days after becoming an Access Person, a personal holding statement in the form prescribed by the CCO, which contains all the information required under Rule 17j-1(d)(i) and covers not only the personal holdings of the Access Person but certain of their family members and dependants (“Associated Persons”); and |
| ● | annually certain information concerning their and their Associated Persons’ personal holdings in the form prescribed by the CCO, which contains all the information required under Rule 17j-1(d)(iii). |
B. MGL Pre-Clearance Requirements
The most recent version of MGL’s pre-clearance requirements can be found at the below link. MGL policies are updated from time to time and Access Persons are required to periodically check for these updates:
http://macnet.internal.macquarie.com/central/employment/ppc/compliance/personal-deal
C. MIMEL Pre-Clearance Requirements
MIMEL’s pre-clearance requirements help to protect Access Persons and MIMEL against the following critical transgressions:
| ● | Access Persons taking advantage of opportunities more properly belonging to MIMEL clients; |
| ● | Access Persons violating MIMEL’s Code of Ethics requirements as established by the Securities and Exchange Commission (SEC); |
| ● | Access Persons violating insider trading laws; and |
| ● | Access Persons engaging in front running. |
The MIMEL pre-clearance requirements are dictated by the Macquarie Group Personal Dealing Policy.
Please note, you must always pre-clear the direct or indirect acquisition of any beneficial ownership interest in any security in an initial public offering (IPO) and private placement of securities. Also, you must always pre-clear trades in the shares of any Funds managed by MIMEL.
Typically, accounts that contain securities that need to be pre-cleared are held in the name(s) of the Access Persons themselves. However, if you, as an Access Person, advise anyone who is not an Access Person (other than clients of MIMEL) on trading in any securities that are not on the Exempt from Pre-Clearance list, these transactions may need to be pre-cleared. You must advise the MIMEL CCO or designee before rendering this investment advice.
Independent directors of any Fund are expressly excluded from the definition of Access Person under Rule 17j-1(d)(2)(ii) for purposes of providing initial or annual reports of their holdings, or quarterly reports of their trading activity in Covered Securities covered by this Code and for pre-clearing their trades, except for the direct or indirect acquisition of any beneficial ownership interest in any security in an initial public offering (IPO) and private placements of securities.
The decision to approve a pre-clearance request lies solely in the discretion of MIMEL’s CCO or designee.
All Access Persons and their Immediate Family Members are prohibited from trading a security in their personal brokerage accounts for seven (7) calendar days before and after Macquarie executes a buy or sell transaction in that same security.
The MIMEL CCO is subject to the above requirements.
(3) Buying and Selling Shares in MIMEL’s Client Accounts
Because MIMEL’s Client Accounts may be listed and trading on a national securities exchange, they are freely tradable. However, as an Access Person has access to material, non-public information regarding such Client Accounts, trading in these Client Accounts is severely limited. The CCO will make a determination on such trading on a case by case basis.
(4) Your Trading Window
MIMEL pre-clearance is valid for the day of request only and shall be deemed to expire at the close of regular trading on the principal trading market for the security involved. Any unfilled or partially filled orders will require MIMEL pre-clearance on each subsequent day that the order remains open.
(5) Minimum Holding Period
There is a minimum holding period of thirty calendar days before you may sell, dispose, close out or otherwise vary an interest in a financial instrument subject to Macquarie’s Personal Investment Policy.
D. MIMEL Access Person Reporting and Certifications
(1) New Access Persons
All new Access Persons must trade through a Macquarie broker-dealer. Certain exemptions to this requirement may be approved by RMG and activity statements must be made available to RMG.
If the Access Person, as a part of his or her employment compensation with MGL or any of its subsidiaries or affiliates, received MGL options, the holding of these options is not reportable; however, once these options are exercised, they are reportable in the Access Person’s quarterly transaction reports, as discussed in Paragraph C.(2) below.
Typically, accounts that contain Reportable Securities and/or Covered Securities are held in the name(s) of the Access Persons themselves. However, if you, as an Access Person, are advising one or more persons or entities who are not themselves Access Persons (other than MIMEL clients) on their securities trading or have control of such account(s), please advise the MIMEL CCO or designee at the time you start advising as such. These accounts may be subject to pre-clearance and reporting obligations as well.
(2) Ongoing Quarterly Transactions Monitoring
The SEC requires MIMEL to collect from its Access Persons on a calendar quarterly basis reports that reflect all transactions that took place during the prior quarter:
| ● | in reportable securities beneficially owned, directly or indirectly, by its Access Persons; and/or |
| ● | over which the Access Person had control. |
RMG will have access to trading activity statements for all staff and enabling them to surveil for improper trades and other trades that could create the perception of any improprieties. The CCO may request trading activity statement for all staff directly from RMG.
The following information may be reviewed for all Access Persons:
| ● | The date of the transaction; |
| ● | The security description, and as applicable, the exchange ticker or CUSIP number; |
| ● | Number of shares or par value; |
| ● | Principal amount of the securities; |
| ● | Whether the transaction was a purchase or sale or any other type of acquisition/disposition; |
| ● | The price at which the transaction was effected; |
| ● | Interest rate and maturity rate; |
| ● | The name of the broker, dealer or bank with or through which the transaction was effected; and |
| ● | The date the report is submitted. |
IV. Gifts and Entertainment1
Generally, Access Persons may not give or receive any gifts in connection with any business of MIMEL because it may appear improper or raise a potential conflict of interest. However, gifts may be allowed providing they fall within the Macquarie Gifts and Entertainment Policy. This includes normal and customary business entertainment, the cost of which would be paid for by MIMEL as a reasonable expense if not paid for by the other party. While “nominal value” is susceptible to interpretation, a gift or entertainment is not acceptable if an independent third party may believe that the Access Person would be influenced by receiving such gift or entertainment in conducting business. Gifts of an extraordinary or extravagant nature to an Access Person should be declined or returned in order to avoid compromising the reputation of the Access Person or MIMEL.
1 This section does not apply to any clients’ Independent Directors.
When an access person gives or receives a gift or entertainment, he/she must ensure that this is recorded in the EMEA Gifts Register and that pre-approval is sought where required as per the Macquarie Gifts and Entertainment Policy.
Access Persons must comply with the MGL Dealing with Public Officials’ policy.
If you have any questions about the propriety of a gift you may be offered or may wish to offer to another or any other arrangement, please consult MIMEL’s CCO.
V. Service on a Board of Directors
An Access Person may serve on the Board of Directors of a publicly traded company (the “Board”) only if:
| 1. | The CCO, or designate, determines that serving on the Board would be consistent with the interests of MIMEL; |
| 2. | Appropriate “” “information barrier” procedures are established; and |
| 3. | The CCO, or designate, provides written authorization that the Access Person can serve on the Board. |
VI. OUTSIDE BUSINESS ACTIVITIES
All employees are required to devote their full time and efforts to the Macquarie Group’s business. In addition, no person may make use of either his or her position as an employee or information acquired during employment, or make personal investments in a manner that may create a conflict, or the appearance of a conflict, between the employee’s personal interests and MIMEL' interests.
An employee must complete the Notice of Outside Business Activity disclosure form attached and obtain the written approval of the employee’s supervisor. prior to participating in any outside business activities, including, but not limited to:
| ● | Serving as a director, officer, general partner or trustee of, or as a consultant to, any business, corporation or partnership. |
| ● | Serving as a registered representative of any broker-dealer. |
| ● | Making any monetary investment in any non-publicly traded business, corporation or partnership, including passive investments in private companies. (Investments in publicly traded companies may require prior approval of the Compliance Officer, in accordance with personal securities trading procedures described above). |
| ● | Accepting a second job or part-time job of any kind or engaging in any other business outside of the firm. |
| ● | Forming or participating in any bank group in connection with a bankruptcy or distressed situation. |
| ● | Forming or participating in any committee in making demands for changes in the management or policies of any company, or becoming actively involved in a proxy contest. |
| ● | Receiving compensation of any nature, directly or indirectly, from any person, firm, corporation, estate, trust or association, other than MIMEL, whether as a fee, commission, bonus or other consideration such as stock, options or warrants. |
COMPLIANCE and SANCTIONS
If you become aware of or suspect any violations of this Code, you must report them to the MIMEL CCO as soon as practicable. Reports may be made anonymously. MIMEL has zero tolerance for reprisals against employees making reports, in good faith, of perceived wrongdoing.
The CCO, or designate, shall review the records obtained pursuant to this Code to ensure that all MIMEL Access Persons are complying with its provisions. All records shall be maintained in accordance with Rules 204-2 under the Investment Advisers Act of 1940 and 17j-1(f) under the 1940 Act, as further described in MIMEL’s compliance manuals.
MIMEL may, as they deem appropriate, impose sanctions, including, inter alia, a fine, letter of censure, revoking personal securities trading privileges, suspension or termination of employment of any Access Person who violates any provision of this Code.
As Of Filer Filing For·On·As Docs:Size Issuer Filing Agent 4/09/24 Delaware Group Income Funds 485BPOS 4/09/24 4:34M Pietrzykowski Kris… R/FA 11/30/23 Delaware Group Income Funds 485BPOS 11/30/23 29:9.4M Digital Publishi… Inc/FA 5/01/23 Delaware Group Income Funds N-14/A 8:5.9M Pietrzykowski Kris… R/FA 3/09/23 Delaware Group Income Funds N-14 10:5.9M Gabalawi Matthew/FA 11/28/22 Delaware Group Income Funds 485BPOS 11/28/22 29:8.6M Digital Publishi… Inc/FA 11/24/21 Delaware Group Income Funds 485BPOS 11/24/21 22:8.1M Digital Publishi… Inc/FA 8/03/21 Delaware Group Government Fund 497 8/03/21 1:2M DG3/FA 8/03/21 Delaware Group Income Funds 497 8/03/21 1:2M DG3/FA 8/03/21 Delaware Gp Ltd.-Term Gov’t Funds 497 8/03/21 1:2M DG3/FA |