EX-24.1 5 exhibit24-1.htm CODE OF CONDUCT

展品 24.1

行為守則

請查看附件。

景順寶盛資本管理有限責任公司
道德守則

(於2009年1月生效修訂)

景順Powershares資本管理有限責任公司（「景順PowerShares」）及其全部或間接子公司與所管理的每個投資組合之間存在受託關係。客戶及Powershares etf客戶的股東的利益優於Covered Persons（下文定義）的個人利益。本文件末尾定義了在此使用的大寫字。

本道德守則（以下簡稱“本守則”）適用於所有板塊：

  • 景順PowerShares的員工（廚房工作人員除外）；

  • 任何擁有或被合規部門確定可以獲得或接觸任何INVESCO POWERSHARES實體向其任何客戶提出的建議相關信息（“接觸人員”）的INVESCO POWERSHARES聯屬公司的員工；

  • POWERSHARES基金董事（PowerShares ETF信託基金獨立董事除外）

I. 信託原則聲明

以下受託人原則適用 掩蔽人員。

  • 在任何時候都必須把投資公司客戶的利益和股東放在首位，並且擔任職務的人員不得利用其職位不當；並

  • 所有個人證券交易必須符合本行為守則，並且以避免濫用個人信任和責任的方式進行。這 本行為守則是我們解決業務日常過程中可能出現的利益衝突的努力。

此代碼並未試圖識別所有可能的利益衝突，也並非要求嚴格遵守其各個具體條款。它並不必然保護受覆蓋者免受個人交易或其他違反對客戶和投資公司客戶之受託責任的行為而造成的法律責任。

本規定第IV部分一般而言 處罰違反本規定的行為；本規定的某些部分 專門規定違反該些部分的行為所適用的處罰。

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II. 個人投資的限制

A. 遵守法律、規則和法規；舉報違規行為

所有板塊景順安聯員工均需遵守適用的州和聯邦證券法律、規則和監管要求以及本行內規。員工應立即向景順PowerShares的合規主管或其指定人員報告他們知曉的任何違反法律、規定或本行內規的行為。本行內規第四部分描述了報告潛在違規或合規問題的其他方法。

b. 個人投資

1. 个人安防交易预先批准。所有 除POWERSHARES基金独立董事不了解投资活动外的所有受覆盖人员，必须使用自动请求系统向合规部门预先批准涉及受覆盖证券的所有个人安防交易。

Covered 證券包括（但不限於）景順公司為其客戶進行的所有投資，包括股票、債券、市政債券、賣空榜，以及期權等任何衍生工具。

被覆蓋的證券不包括貨幣市場基金、政府證券、定期存款憑證或開放式共同基金的股份。 不 由景順、POWERSHARES或AIm管理的建議。

雖然AIM 基金被認為是被覆蓋的證券，但那些在Invesco Aim的轉移代理人（AIM基金直接帳戶）或在IVZ 401(k)和Money Purchase計劃中持有的（不包括道富銀行共同基金窗口）不需要通過STAR合規系統預先批准，因為這些證券的合規監控是通過另一個流程進行的。在外部券商帳戶或道富銀行共同基金窗口中持有的AIM基金必須通過STAR合規系統預先批准。請參考第II.b節，了解景順有關證券的指南。

如果您對於某筆拟议交易是否为覆盖證券存有疑问，請在执行该交易之前透过電子郵件聯繫合規部門，電郵地址為CodeofEthics(Northamerica)@景順.com，或致電道德准則熱線877.331.2633。

准許Covered Person執行個人安防的任何批准，僅在該營業日有效。 除非在交易日結束後請求批准，否則授權僅在當天有效。 交易日結束後如有請求批准，授權將有效至以下交易 日。 次一交易日之前的任何授予批准仍有效。

自動審查系統將根據以下考量審查被覆蓋者的個人交易請求：

  • 封闭期景順 POWERSHARES不允許涉及人士 (除了POWERSHARES基金獨立董事不知情 投資活動之外)進行安防交易，如果客戶在交易之前或之后的最後兩天內 或者目前有訂單在交易櫃檯上。例如， 如果客戶星期一交易，則封闭期內（除了POWERSHARES基金 獨立董事不知情投資活動）可能要等到星期四才能進行交易。

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  • 投資 人員。投資人員在客戶交易該安防前後的三個業務日內，不得買入或賣出被覆蓋的安防。

  • 微不足道 例外。合規部門將在授予事先批准時，應用以下微不足道的例外，當客戶最近交易或正在交易涉及被覆蓋人士提議的個人交易的安防時：

    • 股權微不足道 例外。如果被覆蓋人士對特定股票的交易活動沒有了解，則在滾動30天期間內可執行該安防最多500股，前提是該安防的發行人包含在羅素1000指數中。

    • 固收微不足道 例外。如果被覆蓋人士對特定固收安防的交易活動沒有了解，則他或她可以在一個抵押值為10萬美元的安防上執行最多100,000美元的交易。

自動審查系統將確認目前在與建議的個人交易涉及的安防交易台上沒有活動，並檢查投資組合會計系統，以驗證最近兩個交易日內沒有針對所請求的安防交易進行任何交易。對於IT和投資組合管理人員，合規部門還將檢查附屬公司的交易活動，以核實有關人員可以獲得信息，以驗證最近兩個交易日內沒有針對所請求的安防進行任何交易。合規部門將通知受限人員批准或拒絕建議的個人交易。個人證券交易的批准為僅僅 有效一個業務日。如果受限人員在獲得批准的業務日不執行建議的證券交易，則受限人員必須在第二天重新提交請求以獲得批准。 該業務日。如果受限人員在獲得批准的業務日不執行建議的證券交易，則受限人員必須在第二天重新提交請求以獲得批准。

Any failure to preclear transactions is a violation of the Code and will be subject to the following potential sanctions:

  • A Letter of Education will be provided to any Covered Person whose failure to preclear is considered immaterial or inadvertent.

  • Repeat violations may result in in-person training, probation, withdrawal of personal trading privileges or termination, depending on the nature and severity of the violations.

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2. Prohibition on Short-Term Trading Profits. Covered Persons (other than POWERSHARES Funds Independent Trustees without knowledge of investment activity) are prohibited from trading in a Covered Security within 60 days from the date of purchase at a profit. If a Covered Person (other than POWERSHARES Funds Independent Trustees without knowledge of investment activity) trades a Covered Security within the 60 day time frame, any profit from the trade will be disgorged to a charity of INVESCO POWERSHARES’s choice and a letter of education to the Covered Person will be issued.

3. Initial Public Offerings. Covered Persons (other than POWERSHARES Funds Independent Trustees without knowledge of investment activity) are prohibited from acquiring any security in an equity Initial Public Offering. Exceptions will only be granted in unusual circumstances and must be recommended by the Compliance Department and approved by the Chief Compliance Officer or General Counsel (or designee) and the Chief Investment Officer.

4. Prohibition of Short Sales by Investment Personnel. Investment Personnel are prohibited from effecting short sales of Covered Securities in their personal accounts if an Invesco PowerShares Client for whose account they have investment management responsibility has a long position in those Securities.

5. Restricted List Securities. Covered Persons requesting pre-clearance to buy or sell a security on the Restricted List may be restricted from executing the trade because of potential conflicts of interest.

6. Brokerage Accounts. Covered Persons (other than POWERSHARES Funds Independent Trustees without knowledge of investment activity) may only maintain brokerage accounts with

  • discount broker-dealers that provide electronic feeds of confirms and monthly statements directly to the Compliance Department,

  • Invesco Aim broker-dealers, or

  • Full service broker-dealers. Covered Persons may own shares of AIM Funds that are held at a non-Invesco Aim broker-dealers only if those broker-dealers provide an electronic feed of all transactions and statements to Invesco Aim’s Compliance Department. All Covered Persons (other than AIM Funds Independent Trustees without knowledge of investment activity) must arrange for their broker-dealers to forward to the Compliance Department on a timely basis, duplicate confirmations of all personal securities transactions and copies of periodic statements for all brokerage accounts, in an electronic format if they include holdings in AIM Funds and preferably in electronic format for holdings other than AIM Funds.

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Please refer Addendum I for a list of broker-dealers that currently provide electronic transaction and statement feeds to Invesco Aim.

7. Reporting Requirements.

a. Initial Holdings Report. Within 10 days of becoming a Covered Person (other than AIM Funds Independent Trustees without knowledge of investment activity), each Covered Person must complete an Initial Holdings Report by inputting into STAR Compliance the following information (the information must be current within 45 days of the date the person becomes a Covered Person).

  • A list of each security including the security name, number of shares (for equities) and the principal amount (for debt securities) in which the person has direct or indirect Beneficial Ownership;

  • The name of any broker-dealer or bank with which the person maintains an account in which any securities are held for the direct or indirect benefit of the person; and

  • The date that the report is submitted by the person.

Independent Trustees of the POWERSHARES Funds do not need to make an initial holdings report.

b. Quarterly Transaction Reports. All Covered Persons (other than POWERSHARES Funds Independent Trustees) must report, no later than 30 days after the end of each calendar quarter, the following information for all transactions in a Covered Security in which a Covered Person has a direct or indirect beneficial interest: This includes any Covered Securities held in a 401(k) or other retirement vehicle outside of the Invesco Aim broker-dealer.

  • The date of all transactions in that quarter, the security name, the number of shares (for equity securities); or the interest rate and maturity date (if applicable) and the principal amount (for debt securities) for each Covered Security;

  • The nature of the transaction (buy, sell, etc.);

  • The price of the Covered Security at which the transaction was executed;

  • The name of the broker-dealer or bank executing the transaction; and

  • The date that the report is submitted to the Compliance Department.

All Covered Persons (other than POWERSHARES Funds Independent Trustees) must submit a quarterly report regardless of whether they have executed transactions during the quarter or not. If a Covered Person did not execute transactions subject to reporting requirements during a quarter, the report must include a representation to that effect. Covered Persons need not include transactions made through an Automatic Investment Plan (systematic transaction-i.e. systematic purchase, systematic exchange, systematic redemption) in the quarterly transaction report.

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Additionally, Covered Persons (other than POWERSHARES Funds Independent Trustees) must report the information on any new brokerage account established by the Covered Person during the quarter for the direct or indirect benefit of the Covered Person (including Covered Securities held in a 401(k) or other retirement vehicle) including:

  • The date the account was established;

  • The name of the broker-dealer or bank; and

  • The date that the report is submitted to the Compliance Department.

An Independent Trustee of an POWERSHARES Fund must report a transaction in a Covered Security in a quarterly transaction report if the trustee, at the time of that transaction, knew or, in the ordinary course of fulfilling his/her duties as a trustee of the POWERSHARES Fund, should have known that, during the 15-day period immediately before or after the date of the transaction by the trustee, the Covered Security was purchased or sold by the POWERSHARES Fund or was being considered by the POWERSHARES Fund or INVESCO POWERSHARES for purchase or sale by the POWERSHARES Fund or another Client.

The Compliance Department may identify transactions by Covered Persons that technically comply with the Code for review based on any pattern of activity that has an appearance of a conflict of interest.

c. Annual Holdings Reports. All Covered Persons (other than POWERSHARES Funds Independent Trustees) must report annually the following information, which must be current within 45 days of the date the report is submitted to the Compliance Department:

  • The security and the number of shares (for equities) or the interest rate and maturity date (if applicable) and principal amount (for debt securities) for each Covered Security in which the Covered Person has any direct or indirect Beneficial Ownership;

  • The name of the broker-dealer or bank with or through which the transaction was effected; and

  • The date that the report is submitted by the Covered Person to the Compliance Department.

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d. Managed Accounts. Covered Persons must make an annual report with respect to transactions held in an account over which the Covered Person has granted exclusive discretion to an external money manager (professionally managed accounts). Covered Persons must receive approval from the Compliance Department to establish and maintain such an account. Covered Persons are not required to pre-clear transactions or submit quarterly reports for such managed accounts; however, Covered Persons with these types of accounts must provide an annual certification that they do not currently and have not in the past exercised direct or indirect Control over the managed accounts.

e. Annual Certification. All Covered Persons (other than POWERSHARES Funds Independent Trustees) must certify annually that they have read and understand the Code and recognize that they are subject to the Code. In addition, all Covered Persons must certify annually that they have complied with the requirements of the Code and that they have disclosed or reported all personal securities transactions required to be disclosed or reported under the Code. The POWERSHARES Funds Trustees, including the Independent Trustees, will review and approve the Code annually.

8. Private Securities Transactions. Covered Persons (other than POWERSHARES Funds Independent Trustees without knowledge of investment activity) may not engage in a Private Securities Transaction without first giving the Compliance Department a detailed written notification describing the transaction and indicating whether or not they will receive compensation and obtaining prior written permission from the Compliance Department. Investment Personnel who have been authorized to acquire securities of an issuer in a Private Securities Transaction must disclose that investment to the Compliance Department and the Managing Director (Research and Trading) of INVESCO POWERSHARES when they are involved in a Client’s subsequent consideration of an investment in the same issuer. The Client’s decision to purchase such securities must be independently reviewed by Investment Personnel with no personal interest in that issuer.

9. Limited Investment Opportunities (e.g. private placements, hedge funds, etc.). Covered Persons may not engage in a Limited Investment Opportunities without first giving the Compliance Department a detailed written notification describing the transaction and obtaining prior written permission from the Compliance Department.

10. Excessive Short Term Trading in Funds. Employees are prohibited from excessive short term trading of any mutual fund advised by AIM or INVESCO POWERSHARES and are subject to various limitations on the number of transactions as indicated in the respective prospectus.

       C. Invesco Ltd. Securities

1. No Employee may affect short sales of Invesco Ltd. securities.

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2. For all Covered Persons, transactions, including transfers by gift, in Invesco Ltd. securities are subject to “black-out” periods established by Invesco Ltd. and holding periods prescribed under the terms of the agreement or program under which the securities were received. Non-company issued IVZ Ltd. securities held in outside brokerage accounts are subject to the pre-clearance requirements outlined in section II.A.

3. Holdings of Invesco Ltd. securities in Covered Persons accounts are subject to the reporting requirements specified in Section II.A7 of this Code.

       D. Limitations on Other Personal Activities

1. Board of Directorships. Investment Personnel will not serve on the boards of directors of either a publicly traded company or any other entity without prior written permission from INVESCO POWERSHARES’s Compliance Department. If the directorship is authorized, the individual will be isolated from others making investment decisions concerning the particular company or entity as appropriate.

2. Gift Policy. INVESCO POWERSHARES Employees may not give or accept gifts or invitations of entertainment that may be considered excessive either in dollar value or frequency to avoid the appearance of any potential conflict of interest. Under no circumstances may any Employees give or accept cash or any possible cash equivalent from a broker or vendor.

  • Invitations. INVESCO POWERSHARES employees must report all entertainment with the Compliance Department on a monthly basis. The requirement to report monthly entertainment includes dinners or any other event with the broker or vendor in attendance.

    Examples of invitations that may be excessive in value include Super Bowl tickets, tickets to All-Star games, hunting trips, or ski trips. An occasional ticket to a sporting event, golf outing or concert when accompanied by the broker or vendor may not be excessive. In all cases, entertainment must be reported to the Compliance Department.

    Additionally, INVESCO POWERSHARES Employees may not reimburse brokers or vendors for the cost of tickets that would be considered excessive or for travel related expenses without approval of the Compliance Department.

  • Gifts. INVESCO POWERSHARES Employees are not required to pre-clear gifts. All gifts given or received must be reported to the Compliance Department on a monthly basis. INVESCO POWERSHARES Employees are prohibited from accepting the following:

    • single gifts valued in excess of $100; in any calendar year: or

    • gifts from one person or firm valued in excess of $100 during a calendar year period.

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INVESCO POWERSHARES Employees must report all entertainment (breakfast and lunches in the office need not be reported), including dinners with the broker/vendor in attendance, and gifts to the Compliance Department on a monthly basis.

III. Administration of the Code of Ethics

INVESCO POWERSHARES will use reasonable due diligence and institute procedures reasonably necessary to prevent violations of this Code.

No less frequently than annually, INVESCO POWERSHARES will furnish to the Boards of Trustees of the POWERSHARES Funds, or such committee as it may designate, a written report that:

  • describes significant issues arising under the Code since the last report to the Boards of Trustees, including information about material violations of the Code and sanctions imposed in response to material violations; and

  • certifies that the POWERSHARES Funds have adopted procedures reasonably designed to prevent Covered Persons from violating the Code.

IV. Sanctions

Upon discovering a material violation of the Code, the Compliance Department will notify INVESCO POWERSHARES’s Chief Compliance Officer (CCO). The CCO will notify the Management of Invesco PowerShares of any material violations at the next regularly scheduled meeting.

The Compliance Department will issue a letter of education to the Covered Persons involved in violations of the Code that are determined to be inadvertent or immaterial.

INVESCO POWERSHARES may impose additional sanctions in the event of repeated violations or violations that are determined to be material or not inadvertent, including disgorgement of profits, a letter of censure or suspension, or termination of employment.

V. Exceptions to the Code

INVESCO POWERSHARES’s Chief Compliance Officer (or designee), together with either one of INVESCO POWERSHARES’s General Counsel, Managing Director (of Research and Trading), Chief Executive Officer or Chairman, may grant an exception to any provision in this Code and will report all such exceptions at the next PowerShares Managers meeting.

VI. Definitions

  • INVESCO POWERSHARES Broker-dealer means either Invesco Aim Distributors, Inc. Management;

  • AIM Funds: Generally includes all funds advised or sub-advised by Invesco AIM Advisors, Inc.

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  • Automatic Investment Plan means a program in which regular purchases or sales are made automatically in or from investment accounts in accordance with a predetermined schedule and allocation, including dividend reinvestment plans;

  • Beneficial Ownership has the same meaning as Rule 16a-1(a)(2) under the Securities Exchange Act of 1934, as amended (“the ’34 Act”). To have a beneficial interest, Covered Persons must have a “direct or indirect pecuniary interest,” which is the opportunity to profit directly or indirectly from a transaction in securities. Thus a Covered Person may have Beneficial Ownership in securities held by members of their immediate family sharing the same household (i.e. a spouse and children) or by certain partnerships, trusts, corporations, or other arrangements;

  • Client means any account for which INVESCO POWERSHARES is either the adviser or sub-adviser;

  • Control As defined same meaning as under Section 2(a)(9) of the Investment Company Act, as amended (the “Investment Company Act”);

  • Covered Person means any full or part time Employee of INVESCO POWERSHARES or the POWERSHARES Funds (except kitchen staff),; any full or part time Employee of any INVESCO POWERSHARES affiliates that, in connection with his or her duties, obtains or has access to any information concerning recommendations being made by any INVESCO POWERSHARES entity to any of its Clients (“access persons”); and any interested trustee or director of the POWERSHARES Funds;

  • Covered Security As defined in Section 2 (a)(36) of the Investment Company Act and includes any POWERSHARES Fund or other Client that is advised or sub-advised by INVESCO POWERSHARES. An exchange traded funds (ETF) is considered a Covered Security.

A Covered Security does not include the following:

  • Direct obligations of the Government of the United States or its agencies;

  • Bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements;

  • Any open-end mutual fund not advised or sub-advised by INVESCO POWERSHARES or Invesco AIM; and

  • Employee means any full or part time Employee of INVESCO POWERSHARES or the POWERSHARES Funds, including any consultant or contractor who INVESCO POWERSHARES’s Compliance Department determines to have access to information regarding INVESCO POWERSHARES’s trading activity;

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  • Investment Personnel means any Employee who, in connection with his/her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities by the Client; and

  • IT Personnel means any Employee that is designated to work in the Information Technology Department; and

  • Fund Account Personnel means any Employee that is designated to work in either of the Fund Administration or Portfolio Administration Groups;

  • Full Service Brokerage Firm: A brokerage firm that provides a large variety of services to its clients, including research and advice, retirement planning, tax tips, and much more. It typically does not include discount on-line brokerage firms with limited services.

  • Independent Trustee means a trustee of a fund who is not an “interested person” of the fund within the meaning of Section 2(a)(19) of the Investment Company Act;

  • Initial Public Offering means an offering of securities registered under the Securities Act of 1933, as amended, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Section 13 or 15(d) of the ’34 Act;

  • Private Securities Transaction means any securities transaction outside the regular course, or scope, of an associated person's employment with a member, including, though not limited to, new offerings of securities which are not registered with the Securities and Exchange Commission, provided however that transactions subject to the notification requirements of Rule 3050 of the FINRA’s, NASD’s Conduct Rules, transactions among immediate family members (as defined in the interpretation of the Board of Governors on free-riding and withholding) for which no associated person receives any selling compensation, and personal transactions in investment company and variable annuity securities shall be excluded.

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ANNUAL CERTIFICATION

     The undersigned hereby certifies on behalf of IPCM pursuant to Section IV.D(2) of the Code of Ethics of IPCM that IPCM has adopted procedures that are reasonably necessary to prevent access persons from violating the Code of Ethics.

Date:           
  Chief Compliance Officer, Invesco PowerShares 
       Capital Management LLC 
 
 
   
  Chief Compliance Officer, PowerShares 
       Exchange-Traded Fund Trust 
 
 
   
  Chief Compliance Officer, PowerShares 
       Exchange-Traded Fund Trust 

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Appendix I

WRITTEN ACKNOWLEDGMENT OF CODE OF ETHICS

To the Chief Compliance Officer:

     The undersigned hereby acknowledges receipt of the Code of Ethics of Invesco PowerShares Capital Management LLC and any current amendment thereto.

 
Date:        
 
 
 
  By:   
  Name:  
  Title:  

Appendix II

ANNUAL COMPLIANCE CERTIFICATION

To the Chief Compliance Officer:

     The undersigned hereby certifies that he or she has:

(a) read this Code of Ethics, including any amendments thereto, and understood it;

(b) complied with this Code’s requirement during the past year,

(c) disclosed or reported all personal securities transactions required to be disclosed or reported pursuant to the requirements of this Code; and

(d) reported all violations of this Code and the federal securities laws, as that term is defined in Rule 204A-1, to the Chief Compliance Officer.

 
Date:        
 
 
 
  By:   
  Name:  
  Title:  

EXHIBIT A

INITIAL HOLDINGS REPORT

To the Chief Compliance Officer:

     As of the below date, I held the following position in these securities in which I may be deemed to have a direct or indirect beneficial ownership, and which are required to be reported pursuant to the Code of Ethics of Invesco PowerShares Capital Management LLC.

Title and       Broker/Dealer or
Type   Symbol or No. of   Principal   Bank Where
Security        CUSIP No.        Shares        Amount        Account is Held

 

 

 

 

 

 

 

 

     This report (i) excludes holdings with respect to which I had no direct or indirect influence or control, and (ii) is not an admission that I have or had any direct or indirect beneficial ownership in the securities listed above.

Date:        Signature:   

A-1

EXHIBIT B

SECURITIES TRANSACTION REPORT

For the Calendar Quarter Ended _________________

To the Chief Compliance Officer:

     During the quarter referred to above, the following transactions were effected in securities in which I may be deemed to have had, or by reason of such transaction acquired, direct or indirect beneficial ownership, and which are required to be reported pursuant to the Code of Ethics of Invesco PowerShares Capital Management LLC.

Security             Broker/
(including             Dealer or
interest rate           Nature of   Bank
and Symbol       Principal   Transaction   Through
maturity   or CUSIP   Date of   No. of Amount of (Purchase,       Whom
date, if any)       Number       Transaction       Shares       Transaction       Sale, Other)       Price       Effective

 

 

 

 

 

 

     This report (i) excludes transactions with respect to which I had no direct or indirect influence or control, (ii) excludes transactions effected pursuant to an automatic investment plan, and (iii) is not an admission that I have or had any direct or indirect beneficial ownership in the securities listed above.

Date:        Signature:   

B-1

EXHIBIT C

ACCOUNT ESTABLISHMENT REPORT

For the Calendar Quarter Ended ______________

To the Chief Compliance Officer:

     During the quarter referred to above, the following accounts were established for securities in which I may be deemed to have a direct or indirect beneficial ownership, and is required to be reported pursuant to the Code of Ethics of Invesco PowerShares Capital Management LLC.

  Date
Broker/Dealer or Bank Where   Account Was
Account Was Established Established
 
 
 
 
 
 

Date:        Signature:   

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EXHIBIT D

ANNUAL HOLDINGS REPORT

To the Chief Compliance Officer:

     As of December 31, 2008, I held the following positions in securities in which I may be deemed to have a direct or indirect beneficial ownership, and which are required to be reported pursuant to the Code of Ethics of Invesco PowerShares Capital Management LLC.

        Broker/Dealer
Title and   Symbol     or
Type of or No. of   Principal Bank Where
Security         CUSIP No.         Shares         Amount         Account is Held

 

 

 

 

     This report excludes holdings with respect to which I had no direct or indirect influence or control and is not an admission that I have or had any direct or indirect beneficial ownership in the securities listed above.

Date:        Signature:   

 

Approved April 25, 2007

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