PERSONAL TRADING POLICY
May, 2024
APPLIES TO:
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Lord Abbett Family of Funds |
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Lord Abbett Alternatives Funds |
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Lord Abbett Distributor LLC |
RISKS ADDRESSED BY THIS POLICY
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Client accounts are harmed due to fraudulent and/or deceptive employee personal trading |
RELEVANT LAW AND OTHER SOURCES
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Rule 17j-1 under the Investment Company Act |
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Section 204A of the Investment Advisers Act of 1940 |
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Rule 204A under the Investment Advisers Act |
RELATED POLICIES AND PROCEDURES
At Lord Abbett, we aspire to be the most respected asset manager in the world, admired for our People, Performance, Relationships and Agility. To realize our
vision, it is essential that we remain committed to upholding high ethical and professional standards, and to acting with honesty and integrity — values that have been part of our culture since 1929 and will continue to guide our efforts for
years to come.
This Personal Trading Policy is designed to guide us in our personal investments and to ensure we honor our obligations to our clients,
regulators, and the markets we serve. As trusted stewards of our clients’ assets, each Partner and employee must be transparent about their personal investment accounts, as well as those of family members or dependents.
In creating this Policy, we want to provide the tools and flexibility you need to make personal investments and pursue your financial goals, while upholding
the values of the firm. This Policy applies to all Partners and employees of Lord Abbett and its affiliates, as well as the Independent Board Members of the Lord Abbett Family of Funds and the Lord Abbett Alternatives Funds (referred to herein
collectively as the “Lord Abbett Funds” Funds to the extent described under “Special Rules for Independent Board Members,” This Policy also applies to consultants and temporary employees of Lord Abbett that have achieved their
3-month anniversary of hire and whose duties include access to Lord Abbett’s trading information.
If you
have questions about how this Policy applies to any aspect of your personal trading, please contact: personaltrading@lordabbett.com.
Scope
This Policy applies to all of your personal investment accounts other than your Lord Abbett-sponsored health savings investment account, and includes
brokerage accounts, 401(k)s that can hold securities other than open-end mutual funds, IRAs, any other retirement accounts, and
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance. |
PERSONAL TRADING POLICY
college savings accounts. The Policy also applies to accounts of your spouse or domestic partner, your children, other dependents living in your home, and any
other accounts that you may have control over (e.g., an account of an elderly parent) or beneficially own.
These personal trading rules are intended as a
guide for you to avoid conflicts of interest between firm trading and trading for your own accounts. You should not engage in any activity that would be in contravention to the spirit of the guidelines set forth below.
NOTE: While a fully discretionary account is subject to the Policy (see below), it is not subject to most of the prohibited investment or pre-approval requirements.
Fully Discretionary Accounts
A “fully discretionary account” meets the following requirements:
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You have no direct or indirect influence or control over purchase or sale decisions; |
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You have delegated all investment discretion to an independent third party or fiduciary; and
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You do not share or retain any discretion over purchase or sale decisions. |
If you have a fully discretionary account, you will need to:
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Certify in writing that the account is fully discretionary (when opening a new account or reporting an existing
account when starting employment at Lord Abbett); |
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Provide an updated certification each year as part of the annual compliance certification process; and
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Obtain a similar written certification (initially and annually) from the third party or fiduciary that has
discretion over the account. |
Brokerage Accounts
In an effort to simplify administration for you and Global Compliance, we have pre-approved a number of brokerage firms
that can provide us with electronic reporting and holdings information directly; therefore, we ask that you maintain your brokerage accounts with one of these firms.
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| Approved Brokerage Firms |
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| Bank of America |
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Met life |
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| Citi |
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Morgan Stanley |
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| Edward Jones |
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Raymond James |
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| E*Trade |
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Schwab |
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| Fidelity |
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Stifel Nicolaus |
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| Goldman Sachs |
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TD Ameritrade |
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| JP Morgan |
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UBS |
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| LPL |
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Vanguard |
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| Merrill Lynch |
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Wells Fargo |
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
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PERSONAL TRADING POLICY
If your preferred brokerage firm is not included on this list, it may still be possible to have an account with another firm. Please contact Global Compliance
for more information. To ensure transparency and meet our regulatory obligations, please contact Global Compliance any time you open a new brokerage account, including the self-directed brokerage account option available through your Lord Abbett
401(k) Plan Retirement account. You may begin trading in your new account once your account is disclosed in the Code of Ethics system and set up for automatic brokerage feeds.
Note to New Employees
Please report any existing
brokerage accounts to Global Compliance within 10 days of your start date. If your account is not with one of the approved brokerage firms, please contact our Global Compliance within 30 days of your start date to find out if you can continue to
maintain the account.
If your account is approved, be sure to direct your brokerage firm(s) to send copies of all trade confirmations and
monthly/quarterly statements (paper or electronic) to Global Compliance.
If your account is not approved or you choose to transition to an account of an
approved broker, you will need to close the old account within 60 days. You will also need to obtain pre-approval for the sale of any securities related to closing the account if required below.
Investments and Transactions
As a firm that is committed
to putting the interests of our clients first, we must ensure that our personal trading is done in a professional manner — avoiding conflicts of interest and complying with our legal and regulatory obligations. As a result, you may not trade on
material non-public information (commonly known as “inside information”), including information about the Lord Abbett Funds or other mutual funds advised by Lord Abbett.
In addition, our Personal Trading Policy prohibits certain types of investments and requires that other transactions be
pre-approved. For a complete list of permitted and prohibited investments and related pre-approval requirements, see Appendix A. When determining if pre-approval is necessary, the pre-approval requirements apply across ALL of your brokerage accounts in the aggregate. For example, if you wish to trade 250 shares of a
stock listed on the NYSE in each of two or more brokerage accounts on a single trading day, you would be required to obtain prior approval on the second transaction as the aggregate share amount is 500 shares and exceeds the de minimis exception set
forth in Appendix A.
Pre-approval Requests
Before making any investment, please submit any pre-approval requests to Global Compliance through the Code of Ethics
tile via VantagePoint. If the security you would like to purchase is not listed in the system, you should contact Global Compliance for assistance.
NOTE: There are special pre-approval rules for the receipt and exercise of
options by a spouse or domestic partner who is a director, employee, or consultant of the company issuing the options. These rules are outlined at the end of this Policy; if you have any questions, please contact
personaltrading@lordabbett.com
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
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PERSONAL TRADING POLICY
While you are permitted to make as many requests for pre-approval and trade as often as you like, we expect you to make
sure your personal trading does not interfere with your job performance. Global Compliance monitors personal trading activity, and we may need to restrict your trading activity if it is excessive or interferes with our commitment to our Clients.
There may be times, such as during business emergencies, when we have to suspend the ability to request pre-approval.
Please be aware that your pre-approval lasts until the end of the second business day after the date of approval.
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For example, if you receive pre-approval on Monday, you can trade on that
approval until Wednesday. |
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However, your pre-approval ends immediately if you learn that we are
considering transacting in the same security for a client. |
If the effectiveness of an approval lapses for any reason, you must submit a
new request and receive another approval before you purchase or sell the security.
Special Rule for New Employees
The Chief Legal Officer or Global Chief Compliance Officer may permit new Lord Abbett employees to sell any securities (within an appropriate period of time)
held prior to starting at the firm. Please contact Global Compliance for more information.
Special Rules for Investment Department Personnel
If you work in Investments, you should be aware that there are two blackout periods that apply to you.
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You cannot hold or trade securities of a company for six months if: |
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You participated in non-public investor meetings (for example, earnings
meetings/calls, analyst meetings, etc.) with company management; or |
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You otherwise “cover” or “follow” a company, industry or sector (e.g., Equity Investment
Personnel assigned to a Global Equity mandate should not transact in equity securities) |
Please note: The six-month period runs from the date of the most recent investor meeting or termination of coverage of that company. Web events and other broad forums with company management that are open to buy- and sell-side firms do NOT restrict you.
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You may not trade in any security that requires pre-approval within
7 calendar days before or after we trade in that same security for any client. The Chief Legal Officer or Global Chief Compliance Officer (“CCO”) may exempt any transaction that will not have a material effect on and/or will not
benefit from the client transaction. |
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
4 |
PERSONAL TRADING POLICY
We calculate holding periods based on a “first-in, first-out”
methodology. If you do engage in one of these transactions, any profits you realize will be forfeited to the relevant client(s) or as otherwise determined by Global Compliance.
Short-term Trading Profits
Please note that you may not
profit from the purchase and sale, or the sale and purchase, of the same (or equivalent) securities, within a 30-calendar day period. This restriction does not apply to the following transactions:
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ETFs (except for single-stock ETF) |
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U.S. government and agency securities |
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Money market instruments |
We calculate holding periods based on a “first-in, first-out”
methodology. If you do engage in one of these short-term transactions, any profits you realize will be forfeited to the relevant client(s) or as otherwise determined by Global Compliance.
Holding Periods
You are required to hold shares in all
Lord Abbett Funds (other than a Lord Abbett money market fund or the Lord Abbett Ultra Short Bond Fund) and any funds that are advised or sub-advised by Lord Abbett for a minimum of 30 days after purchase. We
calculate holding periods on a “first-in, first-out” basis.
Please note that there are two exceptions to this holding period requirement:
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The minimum 30-day holding period does not apply to shares of a Lord
Abbett Fund that you exchange for shares of a newly-offered Lord Abbett Fund for a period of up to 90 days after the newly-offered Fund first accepts investments; and |
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Regular, recurring/automatic contributions (such as in your 401(k)) are exempt from the 30-day holding period calculation. |
Reports and Certifications
We collect reports of your portfolio holdings at the start of your employment and annually thereafter, as well as quarterly transaction reports and annual
certifications.
You are required to submit two types of reports:
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an annual report of holdings after the end of each year, and |
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a quarterly report of transactions at the end of each quarter |
Every year, you will be asked to certify certain items, stating:
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You have received, read, and understand this Policy, |
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You recognize you are subject to this Policy, |
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
5 |
PERSONAL TRADING POLICY
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You have complied with the requirements of this Policy, and |
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You have reported all transactions required to be reported. |
You can submit the quarterly/annual reports and certifications through the Code of Ethics tile via VantagePoint prior to the deadlines. To simplify
compliance, the system will send an email to remind you to file (and follow-up reminders, if necessary). You will need to submit these reports, even if you did not have any reportable transactions.
Due Dates for Reports and Certifications
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Filing Due Date |
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Information Current
As Of |
| Initial Holdings Report |
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No later than 10 days after becoming a Lord Abbett employee
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No more than 45 days prior to becoming a Lord Abbett employee
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| Annual Holdings Report |
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January 31st
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Calendar Year End |
| Quarterly Transaction Report |
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No later than 30 days after calendar quarter |
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Calendar Quarter |
| Annual Certification |
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January 31st |
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N/A |
VIOLATIONS AND SANCTIONS
As a firm committed to upholding the highest standards, our goal is to work with everyone to have 100% compliance with this Policy. However, we recognize the
potential for human error and understand that mistakes will happen from time to time. With this in mind:
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We treat mistakes as learning opportunities. |
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We want to make sure you understand why there was a mistake and want to minimize the chances of a repeat mistake
in the future. |
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We also use these mistakes to guide us on future training opportunities. |
If you do make an error and violate this Policy, we expect you to act in a professional manner and report it promptly to Global Compliance. Please note that
Global Compliance monitors your personal trading and may identify violations of the Policy.
While we want to be fair, you should be aware that serious
mistakes, repeated violations, or mistakes that are intentionally made or concealed may require us to take more drastic measures. On occasion, a mistake might be so egregious or frequent that we may impose a financial sanction or suspend or
terminate employment.
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
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PERSONAL TRADING POLICY
ADMINISTRATION OF THE POLICY
Administration and
Enforcement
The CCO is responsible for administering and enforcing this Policy.
Global Compliance is responsible for reviewing transaction and holdings reports, and certifications, as well as for processing
pre-approval requests. In addition, the CCO will determine appropriate procedures for conducting oversight of the Policy.
All personal transactions, holdings reports and pre-approval requests submitted by the CCO will be reviewed by the
Chief Legal Officer.
Board Reporting
The CCO
provides a report each year to each Board of the Lord Abbett Funds. The CCO also will ensure the Board is aware of any other matters under this Policy that require the Board’s attention.
Exemptions
In light of the possible situations where
exceptions should be made, this Policy authorizes our Chief Legal Officer or CCO, and others they designate, to make any exception to this Policy that they believe is consistent with our legal and regulatory obligations and the purposes that
underlie the Policy.
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
7 |
PERSONAL TRADING POLICY
APPENDIX A - TRANSACTION REQUIREMENTS MATRIX
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Reporting
Required? |
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Preapproval
Required? |
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Subject to 30-Day
Short-Term Trading
Profits
Restriction? |
| Funds |
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| Mutual Funds (open-end) not advised or sub- advised by Lord Abbett |
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No |
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No |
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No |
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| Mutual Funds (open-end) advised or sub-advised by Lord Abbett |
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Yes |
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No |
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No (however subject to 30-Day holding period) |
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| Closed-End Funds *(EXCEPT the Lord Abbett Interval Funds which do NOT require pre- clearance) |
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Yes |
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Yes* |
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Yes |
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| Unit Investment Trusts |
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Yes |
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No |
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No |
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| Exchange Traded Funds *(EXCEPT single-stock ETFs which require pre-clearance and are subject to the 30-day Short-Term Trading Profits Restriction) |
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Yes |
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No* |
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No* |
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| Other |
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Yes |
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Yes |
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Yes |
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| Equities* |
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| Common Stock/ADRs: 300* shares or fewer of the following: |
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Yes |
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No |
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Yes |
| - an S&P 500 Index Company; |
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| - a company listed on the NASDAQ; and |
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| - a company listed on the NYSE |
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| * You must aggregate all shares of the same security
across ALL of your brokerage accounts when determining if you meet this exception. For example, if you wish to trade 275 shares of ABC stock in 1 account, and 50 shares of ABC stock in another account,
pre-clearance would be required as you seek to exceed 300 shares in a single trading day.
NOTE: This pre-clearance exception is not intended for consecutively trading less than 300 shares to build larger
positions. This activity is monitored and could be deemed a violation of this Policy. |
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| Common Stock/ADRs: more than 300* shares of the following: |
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Yes |
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Yes |
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Yes |
| - an S&P 500 Index Company; |
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| - a company listed on the NASDAQ; and |
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| - a company listed on the NYSE |
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| * You must aggregate all shares of the same security
across ALL of your brokerage accounts when determining total shares traded. For example, if you wish to trade 275 shares of ABC stock in 1 account, and 50 shares of ABC stock in another account, pre-clearance
would be required as you seek to exceed 300 shares in a single trading day. |
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| Common Stock/ADRs other than shares of the following: |
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Yes |
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Yes |
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Yes |
| - an S&P 500 Index Company; |
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| - a company listed on the NASDAQ; and |
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| - a company listed on the NYSE |
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
8 |
PERSONAL TRADING POLICY
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Reporting
Required? |
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Preapproval
Required? |
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Subject to 30-Day
Short-Term Trading
Profits
Restriction? |
| Stock Dividends and Dividend Reinvestment Plans |
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Yes |
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No |
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No |
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| Warrants/Rights |
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Yes |
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Yes |
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Yes |
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| Preferred Stock |
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Yes |
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Yes |
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Yes |
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| IPOs and Secondaries |
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PROHIBITED |
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PROHIBITED |
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PROHIBITED |
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| Other |
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Yes |
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Yes |
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Yes |
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| Fixed Income |
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| Municipal Bonds |
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Yes |
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Yes |
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Yes |
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| Corporate Bonds |
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Yes |
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Yes |
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Yes |
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| High Yield Bonds |
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Yes |
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Yes |
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Yes |
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| Convertible Bonds |
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Yes |
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Yes |
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Yes |
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| Exchange-Traded Notes |
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Yes |
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No |
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No |
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| Foreign Government issued securities |
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Yes |
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Yes |
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Yes |
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| U.S. Treasuries |
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No |
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No |
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No |
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| Money Market instruments |
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No |
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No |
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No |
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| Other |
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Yes |
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Yes |
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Yes |
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| Options and Futures |
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| Futures or Exchange-Traded Call or Put Options on: |
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| - Currencies, Commodities or ETFs |
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Yes |
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No |
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No |
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| * Writingof Options is only permitted on broad-based ETFs |
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| Futures or Exchange-Traded Call or Put Options on: |
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| - Equity or Fixed Income Securities |
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Yes |
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Yes |
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Yes |
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| * Writingof Options is only permitted on broad-based ETFs |
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| NOTE: The 30-day short-term trading profits rule may affect your ability to close an option position at a profit. |
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| Other |
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PROHIBITED |
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PROHIBITED |
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PROHIBITED |
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| Other Transaction Activity |
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| Short-sales or Purchases on margin |
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PROHIBITED |
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PROHIBITED |
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PROHIBITED |
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| Private Placements |
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Yes |
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Yes |
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Yes |
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| Initial Coin Offerings |
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PROHIBITED |
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PROHIBITED |
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PROHIBITED |
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| Securities connected to activity prohibited by federal law |
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PROHIBITED |
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PROHIBITED |
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PROHIBITED |
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| Securities you are aware are trading/being considered for clients |
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PROHIBITED |
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PROHIBITED |
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PROHIBITED |
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| Securities received via bankruptcy/insolvency/involuntary corporate action |
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Yes |
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No |
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No |
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
9 |
PERSONAL TRADING POLICY
SPECIAL RULES FOR INDEPENDENT BOARD MEMBERS
The Independent Board Members of the Lord Abbett Family of Funds and the Lord Abbett Alternatives Funds (the “Independent Board Members”) are not
subject to this Policy except to the extent specified in these special rules set forth below. The Lord Abbett Family of Funds and the Lord Abbett Alternatives Funds are referred to herein each as a “Fund” and collectively as the
“Funds”).
PRE-APPROVAL AND REPORTING REQUIREMENTS
General
We try to ensure that the Independent
Board Members do not receive information that will subject their personal securities transactions to the requirements of the Policy; therefore, Independent Board Members generally are not required to obtain
pre-approval to purchase or sell securities, or to submit holdings and transaction reports.
However, no
Independent Board Member shall in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by one of the Funds:
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employ any device, scheme or artifice to defraud the Fund; |
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make any untrue statement of a material fact to the Fund or omit to state a material fact necessary in order to
make the statements made to the Fund, in light of the circumstances under which they are made, not misleading; |
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engage in any act, practice or course of business that operates or would operate as a fraud or deceit on the
Fund; or |
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engage in any manipulative practice with respect to the Fund. |
Exception Where Pre-approval is Required
If, at a meeting or otherwise, an Independent Board Member learns of Lord Abbett’s or a Fund’s current or contemplated investment transaction in any
company, then the Independent Board Member must:
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Promptly report this information to our CCO. |
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Obtain preapproval from Global Compliance in accordance with the Policy for any personal securities transactions
in that company during the 30-day period after learning such information. |
Exception Where
Quarterly Transaction Reporting is Required
We require Independent Board Members to submit a quarterly transaction report to the Compliance
Department when they know or reasonably should have known at the time of a transaction in a particular security that a Fund was transacting or considering a transaction in that security during the 15-day
period immediately before or after the date of the transaction (i.e., a total of 30 days). If the Independent Board Member enters into that transaction, he/she must report all securities transactions effected during the quarter for his
or her account or for any account that would be in scope under the Policy.
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
10 |
PERSONAL TRADING POLICY
Other Board Positions
Prior to becoming a director
of any public company, Independent Board Members must inform Lord Abbett’s Managing Partner and discuss whether accepting such appointment will create any conflict of interest or other issues.
Annual Certifications
Independent Board Members
are required to submit annual certifications.
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
11 |
PERSONAL TRADING POLICY
SPECIAL PRE-APPROVAL RULES FOR SPOUSES OR DOMESTIC PARTNERS OF
LORD ABBETT PERSONNEL
Stock Options
The following rules apply to stock options received or exercised by a spouse or domestic partner who is a director or employee of, or a consultant to,
a company providing those options:
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| Preapproval and Quarterly Transaction
Reporting REQUIRED |
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Preapproval and Quarterly Transaction
Reporting NOT REQUIRED |
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| Sale of underlying securities in connection with “cashless” exercise of options by spouse/domestic partner |
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Receipt of options by spouse/domestic partner
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| Sale of underlying securities after initial “cash exercise” of options by spouse/domestic partner |
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Exercise of Options without sale of underlying securities (i.e., “cashless exercise” of options) by spouse/domestic partner |
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| This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or
approved by Lord Abbett Global Compliance.
12 |