N-CSR

Item 1: Report to Stockholders

The following is a copy of the report transmitted to stockholders pursuant
to Rule 30e-1 under the Investment Company Act of 1940:

What makes Putnam different?

In 1830, Massachusetts Supreme Judicial Court Justice Samuel Putnam established The Prudent Man Rule, a legal foundation for responsible money management.

THE PRUDENT MAN RULE

All that can be required of a trustee to invest is that he shall conduct himself faithfully and exercise a sound discretion. He is to observe how men of prudence, discretion, and intelligence manage their own affairs, not in regard to speculation, but in regard to the permanent disposition of their funds, considering the probable income, as well as the probable safety of the capital to be invested.

A time-honored tradition in money management

Since 1937, our values have been rooted in a profound sense of responsibility for the money entrusted to us.

A prudent approach to investing

We use a research-driven team approach to seek consistent, dependable, superior investment results over time, although there is no guarantee a fund will meet its objectives.

Funds for every investment goal

We offer a broad range of mutual funds and other financial products so investors and their advisors can build diversified portfolios.

A commitment to doing what’s right for investors

We have below-average expenses and stringent investor protections, and provide a wealth of information about the Putnam funds.

Industry-leading service

We help investors, along with their financial advisors, make informed investment decisions with confidence.

The Putnam
Fund for Growth
and Income
10 | 31 | 05
Annual Report
Message from the Trustees	2
About the fund	4
Report from the fund managers	7
Performance	13
Expenses	16
Portfolio turnover	18
Risk	19
Your fund’s management	20
Terms and definitions	23
Trustee approval of management contract	25
Other information for shareholders	30
Financial statements	31
Federal tax information	58
Brokerage commissions	59
About the Trustees	60
Officers	66

Cover photograph: Postage stamps, private collection © White-Packert Photography

Message from the Trustees

Dear Fellow Shareholder

During the period that ended October 31, 2005, domestic stocks advanced at a pace reflecting their long-term average returns, while bonds registered sub-par results. Outside the United States, most markets showed more impressive gains. Although U.S. economic growth proceeded at a steady pace, new concerns emerged. High energy prices, the Federal Reserve Board’s program of interest-rate increases, and the impact of the unusually active 2005 hurricane season proved challenging to consumers and sparked brief bouts of volatility in finan-cial markets. Putnam Management believes that energy prices, interest rates, and the aftereffects of this year’s storms are likely to continue to shape investment opportunities and risks in the months to come.

Amid the uncertainties of this environment, the professional research, diversification, and active management that mutual funds provide continue to make them an intelligent choice for investors. We want you to know that Putnam Investments’ management team, under the leadership of Chief Executive Officer Ed Haldeman, continues to focus on investment performance and remains committed to putting the interests of shareholders first. In keeping with these goals, we have redesigned and expanded our shareholder reports to make it easier for you to learn more about your fund. Furthermore, on page 25 we provide information about the 2005 approval by the Trustees of your fund’s management contract with Putnam.

We would also like to take this opportunity to announce the retirement of one of your fund’s Trustees, Ronald J. Jackson, who has been an independent Trustee of the Putnam funds since 1996. We thank him for his service.

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In the following pages, members of your fund’s management team discuss the fund’s performance and strategies, and their outlook for the months ahead. As always, we thank you for your support of the Putnam funds.

The Putnam Fund for Growth and Income:
pursuing capital growth for nearly 50 years

In November 1957 -- almost 20 years to the day after Putnam Investments was founded with the launch of The George Putnam Fund of Boston -- Putnam launched its second mutual fund: The Putnam Fund for Growth and Income.

Putnam’s founders carefully debated the merits of adding a fund whose primary focus would be stock investments. They believed that the balanced approach of The George Putnam Fund of Boston, which owned a mix of stocks and bonds, was still the most prudent choice for most individuals. However, the advent of state tax-exempt bonds was making it more advantageous for some investors to balance their own portfolios. Furthermore, many finan-cial advisors who worked with Putnam had been urging the firm to launch a common stock fund to meet this growing need.

The fund was launched in a favorable environment for stock investors. Confidence in stocks, which had been severely shaken by the 1929 crash and the Great Depression that followed, had finally been renewed in the early 1950s. Fueled by the optimism of new technologies and the race to space, the 1960s were generally good years for investors. Then came the stagflation-plagued 1970s when the stock market moved sideways for most of the decade.

Growth of a $10,000 investment ($9,475 after sales charge)
since fund inception, 11/6/57, through 9/30/05

Plotted on a logarithmic scale
so that comparable percentage
changes appear similar

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The fund benefited from the rallies that dominated the 1980s and 1990s. There were bumps in the road, such as the recession of the early 1990s, and, more recently, the bear market of 2000–2002.

True to its roots, The Putnam Fund for Growth and Income continues to focus on long-term capital growth opportunities among leading large-cap companies with equal attention to managing downside risk. We believe these strategies, which have proven successful for long-term investors in the fund, will continue to serve the fund well as it approaches its 50th year.

In 1957, the year
The Putnam Fund
for Growth and Income
was introduced, the
Dow Jones Industrial
Average closed at just
over 435. At the close
of the fund’s current
fiscal year, the Dow
stood at 10440.

                                                                      

The Putnam Fund for Growth and Income seeks capital growth
and current income by investing primarily in undervalued stocks of large, established, divi-
dend-paying companies. The fund may be appropriate for investors who wish to diversify a
portfolio that emphasizes growth investments.

Highlights 

•  For the 12 months ended October 31, 2005, The Putnam Fund for Growth and Income’s class 

    A shares returned 8.96% without sales charges. 

•  Over the same period, the fund’s benchmark, the S&P 500/Barra Value Index, returned 10.17%. 

•  The average return for the fund’s Lipper category, Large-Cap Value Funds, was 9.75%. 

•  Additional fund performance, comparative performance, and Lipper data can be found in the 

    performance section beginning on page 13. 

Performance

Total return for class A shares for periods ended 10/31/05

Since the fund's inception (11/6/57), average annual return is 12.23% at NAV and 12.10% at POP.
	Average annual return		Cumulative return
	NAV	POP	NAV	POP
10 years	8.30%	7.72%	121.93%	110.32%
5 years	1.69	0.60	8.74	3.02
1 year	8.96	3.25	8.96	3.25

Data is historical. Past performance does not guarantee future results. More recent returns may be less or more than those shown. Investment return and principal value will fluctuate, and you may have a gain or a loss when you sell your shares. Performance assumes reinvestment of distributions and does not account for taxes. Returns at NAV do not reflect a sales charge of 5.25% . For the most recent month-end performance, visit www.putnam.com. A short-term trading fee of up to 2% may apply.

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Report from the fund managers

The year in review

Your fund’s 2005 fiscal year was marked by rising interest rates and infla-tionary pressures, which often create a headwind for stocks. However, the fund delivered what we consider to be respectable returns. Based on results at net asset value (NAV, or without sales charges) the fund kept pace with the broad market S&P 500 Index, which returned 8.72% . However, it lagged its value-oriented benchmark and the average for its peer group, Lipper Large-Cap Value Funds. Relative to these benchmarks, we believe that the fund was less aggressively positioned in the energy sector, the strongest-performing sector during the year. Furthermore, certain portfolio holdings did not perform up to our expectations. We believe these holdings continue to offer attractive long-term potential and may prove more rewarding when the market begins to recognize that they are deeply undervalued.

Market overview

The stock market advanced in an environment of robust corporate earnings growth and healthy profits. At this point in the economic cycle, many companies have reduced their debt levels and are now looking for ways to invest their capital to spur growth and enhance shareholder value. The period saw an increase in merger and acquisition (M&A) activity, as well as higher dividend payouts and accelerated share repurchasing programs. However, there were signs that the rate of economic growth was slowing under the weight of rising short-term interest rates and sustained high energy prices. As of November 1, 2005, the federal funds rate, which is the rate at which banks borrow from each other overnight, had increased a full 3.0% from its level on June 30, 2004, when the Federal Reserve Board (the “Fed”) began its tightening policy. Meanwhile, high energy prices led to an uptick in infla-tion within the energy sector, and raised concerns that inflation could spread to other sectors as well.

Over the course of the year, stock market volatility increased and there was a fair amount of rotation of assets

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between industry sectors. The best-performing sectors included energy, health care, technology, and utilities, particularly those that did not depend on the most expensive fuels -- gas and oil --for power generation. Results for the remaining market sectors were mixed.

Value stocks continued to outperform growth stocks. Smaller-cap stocks prevailed over their larger counterparts. The degree of that outperformance has lessened, however, and we believe that large-cap stocks are poised to take the lead in coming months.

Strategy overview

Your fund’s strategy generally does not change significantly in response to shifting market conditions. We invest in a well-diversified portfolio of undervalued large-cap stocks that we believe offer both attractive dividend income and the potential for long-term capital appreciation. During the year, we focused on holdings that we believed could offer the greatest potential returns and we reduced the number of holdings in the portfolio so that each position could have a more meaningful impact on overall returns.

Over the past six months, we slightly increased the fund’s allocation to finan-cial stocks. Within the financial sector, we reduced positions in capital markets stocks and redeployed those assets into other financial stocks. Property and casualty insurance stocks were attractive because of their low price-to-earnings and price-to-book valuations, and we believe the industry will be able to grow profitably in the next several years.

Market sector performance

These indexes provide an overview of performance in different market sectors for the 12 months ended 10/31/05.

Equities
S&P 500/Barra Value Index (large-company value stocks)	10.17%
Russell 1000 Growth Index (large-company growth stocks)	8.81%
S&P 500 Index (broad stock market)	8.72%
MSCI World Index (global stocks)	13.27%
Bonds
Lehman Aggregate Bond Index (broad bond market)	1.13%
Lehman Intermediate Treasury Bond Index (intermediate-maturity U.S. Treasury bonds)	0.00%
Lehman Municipal Bond Index (tax-exempt bonds)	2.54%

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Hurricanes Katrina and Rita struck after we had boosted our insurance exposure, but it is our opinion that these natural disasters may actually benefit the insurers in the intermediate term as these costs are passed along in the form of higher premiums. We further believe banking stocks will strengthen when the Federal Reserve Board stops raising interest rates, and so we have increased exposure to certain banks in order to take advantage of what we see as their current low valuations.

Your fund’s holdings

Among the top contributors to portfolio returns for the period was Altria Group, a long-term holding for the fund. Altria has benefited from significant positive developments in its legal battles over selling tobacco products. A number of important rulings have limited the scope of potential damages. At the same time, the company’s business has improved and investors have bid the stock price up throughout the period, anticipating that the company may eventually reconfigure itself into separate divisions. Integrated oil company Exxon Mobil continued to be a strong performer, and we trimmed that position somewhat during the last six months of the fiscal year in order to lock in profits.

During fiscal 2004, we established a position in Express Scripts, a pharmacy benefit management company. We built that position through much of the year. The stock performed exceedingly well in fiscal 2005, benefiting from an increase in demand for generic drugs and a focus

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on health-care cost control measures. We had begun to take profits by the end of the period. Another key contributor from the health-care sector was CIGNA, a health maintenance organization. Its costs rose less than many had expected, leading to better profits and a rising stock price. Office Depot, the number-two office supply retailer, also contributed positively to results during the period. The stock was previously out of favor due to a lack of confidence in its management. The advent of a new CEO with a proven talent for increasing earnings and profits spurred a favorable market reaction. The stock rebounded strongly over the summer months. We sold some shares to lock in profits, but are maintaining a position in expectation of future growth.

Among the portfolio’s technology holdings, Hewlett-Packard (HP) and Motorola enjoyed strong performance and boosted portfolio returns. HP, which had been struggling, posted two consecutive quarters of improving profitability under its new CEO. Electronics manufacturer Motorola is also enjoying a strong recovery under its new CEO, who implemented cost-control measures and improved profitability.

Pfizer, Fannie Mae, Tyco International, and Masco were among the stocks that did not live up to our expectations during the period and detracted from relative returns. Pfizer felt the pressure of upcoming patent expirations on some of its blockbuster drugs, as well as a decrease in its sales volume resulting from competition

Top holdings

This table shows the fund's top holdings, and the percentage of the fund's net assets that each comprised, as of 10/31/05. The fund's holdings will change over time.

Holding (percent of fund's net assets)	Industry
Citigroup, Inc. (4.0%)	Financial
Bank of America Corp. (3.9%)	Banking
American International Group, Inc. (2.7%)	Insurance
Altria Group, Inc. (2.7%)	Tobacco
Exxon Mobil Corp. (2.6%)	Oil and gas
Pfizer, Inc. (2.6%)	Pharmaceuticals
General Electric Co. (2.4%)	Conglomerates
Johnson & Johnson (2.3%)	Pharmaceuticals
Lockheed Martin Corp. (2.2%)	Aerospace and defense
U.S. Bancorp (2.2%)	Banking

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from generic drugs. We continue to hold a position because we believe the stock is extremely undervalued and represents a solid long-term opportunity. The changing regulatory environment for mortgage reseller Fannie Mae is causing much uncertainty. The share price is now extremely low in our opinion, and we believe this stock offers substantial potential for gains over the long term. Our relatively large position in Tyco International was a positive contributor for several quarters. The company missed an earnings target during the fiscal year, however, which caused the stock price to tumble. A certain amount of volatility is to be expected as a company executes a turnaround, and in our view, this company’s long-term prospects remain very favorable. Masco, which produces building materials and paints, faced higher prices for its raw materials. As a result, profit margins were squeezed and the market punished the stock. We believe this is a short-term obstacle and we are maintaining a position.

Please note that the holdings discussed in this report may not have been held by the fund for the entire period discussed, are subject to review in accordance with the fund’s investment strategy, and may vary in the future.

Of special interest

In June 2005, the fund’s Trustees voted to increase the dividend rate on class A shares of The Putnam Fund for Growth and Income by 40%, or $0.02 per share. The new dividend on class A shares is $0.07. Dividends on other share classes also increased. The dividend increase reflects general growth in dividends received from the portfolio’s holdings.

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The outlook for your fund

The following commentary reflects anticipated developments that could affect your fund over the next six months, as well as your management team’s plans for responding to them.

We believe that the Fed may be nearing the end of its tightening policy. If we are correct, this would be a positive development for stocks, which generally struggle in a rising-rate environment. We believe that inflation in the energy sector is a temporary difficulty, but we are concerned that high energy prices could spark inflation throughout the economy, and we remain watchful. After three years of recovery, the economy is growing at what we believe is a moderate pace, and we anticipate that this rate of growth will slow.

An interesting theme has developed among larger companies: Stock valuations are actually lower now than they were a year ago, because earnings, dividends, and cash flows have increased more than stock prices. In our opinion, many large-cap stocks now offer an attractive combination of above-average dividend yields and projected dividend growth, have price-to-earnings ratios that are lower than the market average, and have better-than-average long-term prospects. This type of stock is well represented in your fund’s portfolio, and we believe they offer strong potential for attractive returns over time. As always, we remain committed to helping you pursue your investment goals and we believe The Putnam Fund for Growth and Income can serve as the core fund in a diversified portfolio.

The views expressed in this report are exclusively those of Putnam Management. They are not meant as investment advice.

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Your fund’s performance

This section shows your fund’s performance during its fiscal year, which ended October 31, 2005. In accordance with regulatory requirements, we also include performance for the most current calendar quarter-end. Performance should always be considered in light of a fund’s investment strategy. Data represents past performance. Past performance does not guarantee future results. More recent returns may be less or more than those shown. Investment return and principal value will fluctuate, and you may have a gain or a loss when you sell your shares. For the most recent month-end performance, please visit www.putnam.com or call Putnam at 1-800-225-1581. Class Y shares are generally only available to corporate and institutional clients. See the Terms and Definitions section in this report for definitions of the share classes offered by your fund.

Fund performance
Total return for periods ended 10/31/05
	Class A		Class B		Class C		Class M		Class R	Class Y
(inception dates)	(11/6/57)		(4/27/92)		(7/26/99)		(5/1/95)		(1/21/03)	(6/15/94)
	NAV	POP	NAV	CDSC	NAV	CDSC	NAV	POP	NAV	NAV
Annual average
(life of fund)	12.23%	12.10%	11.19%	11.19%	11.39%	11.39%	11.47%	11.39%	11.94%	12.29%
10 years	121.93	110.32	105.93	105.93	106.01	106.01	111.08	103.71	116.42	127.61
Annual average	8.30	7.72	7.49	7.49	7.50	7.50	7.76	7.37	8.03	8.57
5 years	8.74	3.02	4.70	2.74	4.68	4.68	6.05	2.35	7.37	10.10
Annual average	1.69	0.60	0.92	0.54	0.92	0.92	1.18	0.47	1.43	1.94
1 year	8.96	3.25	8.15	3.15	8.18	7.18	8.41	4.63	8.70	9.28

Performance assumes reinvestment of distributions and does not account for taxes. Returns at public offering price (POP) for class A and M shares reflect a sales charge of 5.25% and 3.50%, respectively (which for class M shares does not reflect a reduction in sales charges that went into effect on April 1, 2005; if this reduction had been in place for all periods indicated, returns would have been higher). Class B share returns reflect the applicable contingent deferred sales charge (CDSC), which is 5% in the first year, declining to 1% in the sixth year, and is eliminated thereafter. Class C shares reflect a 1% CDSC the first year that is eliminated thereafter. Class R and Y shares have no initial sales charge or CDSC. Performance for class B, C, M, R, and Y shares before their inception is derived from the historical performance of class A shares, adjusted for the applicable sales charge (or CDSC) and, except for class Y shares, the higher operating expenses for such shares.

A 2% short-term trading fee may be applied to shares exchanged or sold within 5 days of purchase.

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Change in the value of a $10,000 investment ($9,475 after sales charge)
Cumulative total return from 10/31/95 to 10/31/05

Past performance does not indicate future results. At the end of the same time period, a $10,000 investment in the fund’s class B and class C shares would have been valued at $20,593 and $20,601, respectively, and no contingent deferred sales charges would apply. A $10,000 investment in the fund’s class M shares would have been valued at $21,108 ($20,371 at public offering price). A $10,000 investment in the fund’s class R and class Y shares would have been valued at $21,642 and $22,761, respectively. See first page of performance section for performance calculation method.

Comparative index returns
For periods ended 10/31/05

		Lipper Large-Cap
	S&P 500/Barra	Value Funds
	Value Index	category average*
Annual average
(life of fund)	--†	--†
10 years	154.94%	139.86%
Annual average	9.81	9.01
5 years	8.14	13.29
Annual average	1.58	2.40
1 year	10.17	9.75

	Index and Lipper results should be compared to fund performance at net asset value.
*	Over the 1-, 5-, and 10-year periods ended 10/31/05, there were 443, 247, and 114 funds, respectively, in this Lipper category.
†	The fund's benchmark and Lipper category were not in existence at the time of the fund's inception.
	The S&P 500/Barra Value Index commenced 12/31/74. The fund's Lipper category commenced 12/31/59.

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Fund price and distribution information
For the 12-month period ended 10/31/05

	Class A		Class B	Class C	Class M		Class R	Class Y
Distributions
(number)	4		4	4	4		4	4
Income	$0.2431		$0.0951	$0.0951	$0.1441		$0.2111	$0.2921
Capital gains
Long term	$0.0259		$0.0259	$0.0259	$0.0259		$0.0259	$0.0259
Short term	--		--	--	--		--	--
Total	$0.2690		$0.1210	$0.1210	$0.1700		$0.2370	$0.3180
Share value:	NAV	POP	NAV	NAV	NAV	POP	NAV	NAV
10/31/04	$18.07	$19.07	$17.80	$17.99	$17.95	$18.60	$18.03	$18.10
10/31/05	19.42	20.50	19.13	19.34	19.29	19.94*	19.36	19.46
Current yield
(end of period)
Current
dividend rate1	1.44%	1.37%	0.65%	0.64%	0.91%	0.88%	1.26%	1.71%
Current 30-day
SEC yield2	1.22	1.16	0.49	0.49	0.73	0.71	0.97	1.47

*	Reflects a reduction in sales charges that took effect on April 1, 2005.
1	Most recent distribution, excluding capital gains, annualized and divided by NAV or POP at end of period.
2	Based only on investment income, calculated using SEC guidelines.

Fund performance for most recent calendar quarter
Total return for periods ended 9/30/05

	Class A		Class B		Class C		Class M		Class R	Class Y
(inception dates)	(11/6/57)		(4/27/92)		(7/26/99)		(5/1/95)		(1/21/03)	(6/15/94)
	NAV	POP	NAV	CDSC	NAV	CDSC	NAV	POP	NAV	NAV
Annual average
(life of fund)	12.30%	12.17%	11.26%	11.26%	11.46%	11.46%	11.54%	11.46%	12.01%	12.36%
10 years	123.27	111.50	107.05	107.05	107.22	107.22	112.35	104.92	117.77	128.97
Annual average	8.36	7.78	7.55	7.55	7.56	7.56	7.82	7.44	8.09	8.64
5 years	14.93	8.89	10.69	8.69	10.66	10.66	12.12	8.19	13.52	16.41
Annual average	2.82	1.72	2.05	1.68	2.05	2.05	2.31	1.59	2.57	3.08
1 year	12.14	6.27	11.29	6.29	11.28	10.28	11.60	7.67	11.87	12.46

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Your fund’s expenses

As a mutual fund investor, you pay ongoing expenses, such as management fees, distribution fees (12b-1 fees), and other expenses. Using the information below, you can estimate how these expenses affect your investment and compare them with the expenses of other funds. You may also pay one-time transaction expenses, including sales charges (loads) and redemption fees, which are not shown in this section and would have resulted in higher total expenses. For more information, see your fund’s prospectus or talk to your financial advisor.

Review your fund’s expenses

The table below shows the expenses you would have paid on a $1,000 investment in The Putnam Fund for Growth and Income from May 1, 2005, to October 31, 2005. It also shows how much a $1,000 investment would be worth at the close of the period, assuming actual returns and expenses.

	Class A	Class B	Class C	Class M	Class R	Class Y
Expenses paid per $1,000*	$ 4.55	$ 8.40	$ 8.40	$ 7.12	$ 5.83	$ 3.26
Ending value (after expenses)	$1,049.30	$1,044.70	$1,044.90	$1,046.40	$1,047.30	$1,050.50

*	Expenses for each share class are calculated using the fund’s annualized expense ratio for each class, which represents the
	ongoing expenses as a percentage of net assets for the six months ended 10/31/05. The expense ratio may differ for each
	share class (see the table at the bottom of the next page). Expenses are calculated by multiplying the expense ratio by the
	average account value for the period; then multiplying the result by the number of days in the period; and then dividing that
	result by the number of days in the year.

Estimate the expenses you paid

To estimate the ongoing expenses you paid for the six months ended October 31, 2005, use the calculation method below. To find the value of your investment on May 1, 2005, go to www.putnam.com and log on to your account. Click on the “Transaction History” tab in your Daily Statement and enter 05/01/2005 in both the “from” and “to” fields. Alternatively, call Putnam at 1-800-225-1581.

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Compare expenses using the SEC’s method

The Securities and Exchange Commission (SEC) has established guidelines to help investors assess fund expenses. Per these guidelines, the table below shows your fund’s expenses based on a $1,000 investment, assuming a hypothetical 5% annualized return. You can use this information to compare the ongoing expenses (but not transaction expenses or total costs) of investing in the fund with those of other funds. All mutual fund shareholder reports will provide this information to help you make this comparison. Please note that you cannot use this information to estimate your actual ending account balance and expenses paid during the period.

	Class A	Class B	Class C	Class M	Class R	Class Y
Expenses paid per $1,000*	$ 4.48	$ 8.29	$ 8.29	$ 7.02	$ 5.75	$ 3.21
Ending value (after expenses)	$1,020.77	$1,016.99	$1,016.99	$1,018.25	$1,019.51	$1,022.03

* Expenses for each share class are calculated using the fund’s annualized expense ratio for each class, which represents the 

ongoing expenses as a percentage of net assets for the six months ended 10/31/05. The expense ratio may differ for each 

share class (see the table at the bottom of this page). Expenses are calculated by multiplying the expense ratio by the 

average account value for the period; then multiplying the result by the number of days in the period; and then dividing that 

result by the number of days in the year 

Compare expenses using industry averages

You can also compare your fund’s expenses with the average of its peer group, as defined by Lipper, an independent fund-rating agency that ranks funds relative to others that Lipper considers to have similar investment styles or objectives. The expense ratio for each share class shown below indicates how much of your fund’s net assets have been used to pay ongoing expenses during the period.

	Class A	Class B	Class C	Class M	Class R	Class Y
Your fund's annualized
expense ratio†	0.88%	1.63%	1.63%	1.38%	1.13%	0.63%
Average annualized expense
ratio for Lipper peer group‡	1.22%	1.97%	1.97%	1.72%	1.47%	0.97%

† For the fund’s most recent fiscal half year; may differ from expense ratios based on one-year data in the financial highlights.

‡ Simple average of the expenses of all front-end load funds in the fund’s Lipper peer group, calculated in accordance with Lipper’s standard method for comparing fund expenses (excluding 12b-1 fees and without giving effect to any expense offset and brokerage service arrangements that may reduce fund expenses). This average reflects each fund’s expenses for its most recent fiscal year available to Lipper as of 9/30/05. To facilitate comparison, Putnam has adjusted this average to reflect the 12b-1 fees carried by each class of shares other than class Y shares, which do not incur 12b-1 fees. The peer group may include funds that are significantly smaller or larger than the fund, which may limit the comparability of the fund’s expenses to the simple average, which typically is higher than the asset-weighted average.

17

Your fund’s
portfolio turnover

Putnam funds are actively managed by teams of experts who buy and sell securities based on intensive analysis of companies, industries, economies, and markets. Portfolio turnover is a measure of how often a fund’s managers buy and sell securities for your fund. A portfolio turnover of 100%, for example, means that the managers sold and replaced securities valued at 100% of a fund’s assets within a one-year period. Funds with high turnover may be more likely to generate capital gains and dividends that must be distributed to shareholders as taxable income. High turnover may also cause a fund to pay more brokerage commissions and other transaction costs, which may detract from performance.

Funds that invest in bonds or other fixed-income instruments may have higher turnover than funds that invest only in stocks. Short-term bond funds tend to have higher turnover than longer-term bond funds, because shorter-term bonds will mature or be sold more frequently than longer-term bonds. You can use the table below to compare your fund’s turnover with the average turnover for funds in its Lipper category.

Turnover comparisons
Percentage of holdings that change every year
	2005	2004	2003	2002	2001
The Putnam Fund for
Growth and Income	53%	29%	33%	30%	37%
Lipper Large-Cap Value Funds
category average	62%	59%	77%	67%	72%

Turnover data for the fund is calculated based on the fund's fiscal-year period, which ends on October 31. Turnover data for the fund's Lipper category is calculated based on the average of the turnover of each fund in the category for its fiscal year ended during the indicated year. Fiscal years vary across funds in the Lipper category, which may limit the comparability of the fund's portfolio turnover rate to the Lipper average. Comparative data for 2005 is based on information available as of 9/30/05.

18

Your fund’s risk

This risk comparison is designed to help you understand how your fund compares with other funds. The comparison utilizes a risk measure developed by Morningstar, an independent fund-rating agency. This risk measure is referred to as the fund’s Overall Morningstar Risk.

Your fund’s Overall Morningstar^® Risk

Your fund’s Overall Morningstar Risk is shown alongside that of the average fund in its broad asset class, as determined by Morningstar. The risk bar broadens the comparison by translating the fund’s Overall Morningstar Risk into a percentile, which is based on the fund’s ranking among all funds rated by Morningstar as of September 30, 2005. A higher Overall Morningstar Risk generally indicates that a fund’s monthly returns have varied more widely.

Morningstar determines a fund’s Overall Morningstar Risk by assessing variations in the fund’s monthly returns - with an emphasis on downside variations - over 3-, 5-, and 10-year periods, if available. Those measures are weighted and averaged to produce the fund’s Overall Morningstar Risk. The information shown is provided for the fund’s class A shares only; information for other classes may vary. Overall Morningstar Risk is based on historical data and does not indicate future results.  Morningstar does not purport to measure the risk associated with a current investment in a fund, either on an absolute basis or on a relative basis. Low Overall Morningstar Risk does not mean that you cannot lose money on an investment in a fund. Copyright 2004 Morningstar, Inc. All Rights Reserved. The information contained herein (1) is proprietary to Morningstar and/or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete, or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information.

19

Your fund’s management

Your fund is managed by the members of the Putnam Large-Cap Value Team. Hugh Mullin is the Portfolio Leader and Joshua Brooks, David King, and Christopher Miller are Portfolio Members of the fund. The Portfolio Leader and Portfolio Members coordinate the team’s management of the fund.

For a complete listing of the members of the Putnam Large-Cap Value Team, including those who are not Portfolio Leaders or Portfolio Members of your fund, visit Putnam’s Individual Investor Web site at www.putnam.com.

Fund ownership by the Portfolio Leader and Portfolio Members

The table below shows how much the fund’s current Portfolio Leader and Portfolio Members have invested in the fund (in dollar ranges). Information shown is as of October 31, 2005, and October 31, 2004.

			$1 –	$10,001 –	$50,001 –	$100,001 –	$500,001 –	$1,000,001
	Year	$0	$10,000	$50,000	$100,000	$500,000	$1,000,000	and over
Hugh Mullin	2005						•
Portfolio Leader	2004					•
Joshua Brooks	2005				•
Portfolio Member	N/A
David King	2005					•
Portfolio Member	2004					•
Christopher Miller	2005					•
Portfolio Member	2004					•
N/A indicates the individual was not a Portfolio Leader or Portfolio Member as of 10/31/04.

20

Fund manager compensation

The total 2004 fund manager compensation that is attributable to your fund is approximately $3,800,000. This amount includes a portion of 2004 compensation paid by Putnam Management to the fund managers listed in this section for their portfolio management responsibilities, calculated based on the fund assets they manage taken as a percentage of the total assets they manage. The compensation amount also includes a portion of the 2004 compensation paid to the Group Chief Investment Officer of the fund’s broader investment category for his oversight responsibilities, calculated based on the fund assets he oversees taken as a percentage of the total assets he oversees. This amount does not include compensation of other personnel involved in research, trading, administration, systems, compliance, or fund operations; nor does it include non-compensation costs. These percentages are determined as of the fund’s fiscal period-end. For personnel who joined Putnam Management during or after 2004, the calculation reflects annualized 2004 compensation or an estimate of 2005 compensation, as applicable.

Other Putnam funds managed by the Portfolio Leader
and Portfolio Members

Joshua Brooks is also a Portfolio Leader of Putnam Research Fund.

David King is also a Portfolio Leader of Putnam Convertible Income-Growth Trust, Putnam
High Income Securities Fund, and Putnam New Value Fund.

Hugh Mullin, Joshua Brooks, Christopher Miller, and David King may also manage other
accounts and variable trust funds advised by Putnam Management or an affiliate.

Changes in your fund’s Portfolio Leader and Portfolio Members

During the year ended October 31, 2005, Portfolio Member Joshua Brooks joined your fund’s
management team.

21

Fund ownership by Putnam’s Executive Board

The table below shows how much the members of Putnam’s Executive Board have invested in the fund (in dollar ranges). Information shown is as of October 31, 2005, and October 31, 2004.

			$1 –	$10,001 –	$50,001–	$100,001
	Year	$0	$10,000	$50,000	$100,000	and over
Philippe Bibi	2005	•
Chief Technology Officer	2004	•
Joshua Brooks	2005				•
Deputy Head of Investments	N/A
William Connolly	2005			•
Head of Retail Management	N/A
Kevin Cronin	2005	•
Head of Investments	2004	•
Charles Haldeman, Jr.	2005			•
President and CEO	2004			•
Amrit Kanwal	2005	•
Chief Financial Officer	2004	•
Steven Krichmar	2005	•
Chief of Operations	2004	•
Francis McNamara, III	2005		•
General Counsel	2004	•
Richard Robie, III	2005	•
Chief Administrative Officer	2004	•
Edward Shadek	2005	•
Deputy Head of Investments	N/A
Sandra Whiston	2005	•
Head of Institutional Management	N/A

N/A indicates the individual was not a member of Putnam’s Executive Board as of 10/31/04.

22

Terms and definitions

Important terms

Total return shows how the value of the fund’s shares changed over time, assuming you held the shares through the entire period and reinvested all distributions in the fund.

Net asset value (NAV) is the price, or value, of one share of a mutual fund, without a sales charge. NAVs fluctuate with market conditions. NAV is calculated by dividing the net assets of each class of shares by the number of outstanding shares in the class.

Public offering price (POP) is the price of a mutual fund share plus the maximum sales charge levied at the time of purchase. POP performance figures shown here assume the 5.25% maximum sales charge for class A shares and 3.50% for class M shares (since reduced to 3.25%) .

Contingent deferred sales charge (CDSC) is a charge applied at the time of the redemption of class B or C shares and assumes redemption at the end of the period. Your fund’s class B CDSC declines from a 5% maximum during the first year to 1% during the sixth year. After the sixth year, the CDSC no longer applies. The CDSC for class C shares is 1% for one year after purchase.

Share classes

Class A shares are generally subject to an initial sales charge and no sales charge on redemption (except on certain redemptions of shares bought without an initial sales charge).

Class B shares may be subject to a sales charge upon redemption.

Class C shares are not subject to an initial sales charge and are subject to a contingent deferred sales charge only if the shares are redeemed during the first year.

Class M shares have a lower initial sales charge and a higher 12b-1 fee than class A shares and no sales charge on redemption (except on certain redemptions of shares bought without an initial sales charge).

Class R shares are not subject to an initial sales charge or CDSC and are available only to certain defined contribution plans.

Class Y shares are not subject to an initial sales charge or CDSC, and carry no 12b-1 fee. They are only available to eligible purchasers, including eligible defined contribution plans or corporate IRAs.

23

Comparative indexes

Lehman Aggregate Bond Index is an unmanaged index of U.S. investment-grade fixed-income securities.

Lehman Intermediate Treasury Bond Index is an unmanaged index of U.S. Treasury securities with maturities between 1 and 10 years.

Lehman Municipal Bond Index is an unmanaged index of long-term fixed-rate investment-grade tax-exempt bonds.

Morgan Stanley Capital International (MSCI) World Index is an unmanaged index of equity securities from developed countries.

Russell 1000 Growth Index is an unmanaged index of those companies in the large-cap Russell 1000 Index chosen for their growth orientation.

S&P 500/Barra Value Index is an unmanaged capitalization-weighted index of large-cap stocks chosen for their value orientation.

S&P 500 Index is an unmanaged index of common stock performance.

Indexes assume reinvestment of all distributions and do not account for fees. Securities and performance of a fund and an index will differ. You cannot invest directly in an index.

Lipper is a third-party industry-ranking entity that ranks mutual funds. Lipper rankings are based on total return at net asset value and do not reflect sales charges. Funds are ranked among other funds with similar current investment styles or objectives as determined by Lipper. Lipper category averages reflect performance trends for funds within a category.

24

Trustee approval of
management contract

General conclusions

The Board of Trustees of the Putnam funds oversees the management of each fund and, as required by law, determines annually whether to approve the continuance of your fund’s management contract with Putnam Management. In this regard, the Board of Trustees, with the assistance of its Contract Committee consisting solely of Trustees who are not “interested persons” (as such term is defined in the Investment Company Act of 1940, as amended) of the Putnam funds (the “Independent Trustees”), requests and evaluates all information it deems reasonably necessary under the circumstances. Over the course of several months beginning in March and ending in June 2005, the Contract Committee met five times to consider the information provided by Putnam Management and other information developed with the assistance of the Board’s independent counsel and independent staff. The Contract Committee reviewed and discussed key aspects of this information with all of the Independent Trustees. Upon completion of this review, the Contract Committee recommended and the Independent Trustees approved the continuance of your fund’s management contract, effective July 1, 2005. This approval was based on the following conclusions:

• That the fee schedule currently in effect for your fund represents reasonable compensation in light of the nature and quality of the services being provided to the fund, the fees paid by competitive funds and the costs incurred by Putnam Management in providing such services, and
• That such fee schedule represents an appropriate sharing between fund shareholders and Putnam Management of such economies of scale as may exist in the management of the fund at current asset levels.

These conclusions were based on a comprehensive consideration of all information provided to the Trustees and were not the result of any single factor. Some of the factors that figured particularly in the Trustees’ deliberations and how the Trustees considered these factors are described below, although individual Trustees may have evaluated the information presented differently, giving different weights to various factors. It is also important to recognize that the fee arrangements for your fund and the other Putnam funds are the result of many years of review and discussion between the Independent Trustees and Putnam Management, that certain aspects of such arrangements may receive greater scrutiny in some years than others, and that the Trustees’ conclusions may be based, in part, on their consideration of these same arrangements in prior years.

Model fee schedules and categories; total expenses

The Trustees’ review of the management fees and total expenses of the Putnam funds focused on three major themes:

25

• Consistency. The Trustees, working in cooperation with Putnam Management, have developed and implemented a series of model fee schedules for the Putnam funds designed to ensure that each fund’s management fee is consistent with the fees for similar funds in the Putnam family of funds and compares favorably with fees paid by competitive funds sponsored by other invest- ment advisors. Under this approach, each Putnam fund is assigned to one of several fee categories based on a combination of factors, including competitive fees and perceived difficulty of management, and a common fee schedule is implemented for all funds in a given fee cate- gory. The Trustees reviewed the model fee schedule currently in effect for your fund, including fee levels and breakpoints, and the assignment of the fund to a particular fee category under this structure. (“Breakpoints” refer to reductions in fee rates that apply to additional assets once specified asset levels are reached.) The Trustees concluded that no changes should be made in the fund’s current fee schedule at this time.
  
  
• Competitiveness. The Trustees also reviewed comparative fee and expense information for competitive funds, which indicated that, in a custom peer group of competitive funds selected by Lipper Inc., your fund ranked in the 8th percentile in management fees and in the 8th percentile in total expenses (less any applicable 12b-1 fees) as of December 31, 2004 (the first percentile being the least expensive funds and the 100th percentile being the most expensive funds). (Because the fund’s custom peer group is smaller than the fund’s broad Lipper Inc. peer group, this expense comparison may differ from the Lipper peer expense information found elsewhere in this report.) The Trustees noted that expense ratios for a number of Putnam funds, which show the percentage of fund assets used to pay for management and administrative services, distribution (12b-1) fees and other expenses, had been increasing recently as a result of declining net assets and the natural operation of fee breakpoints. They noted that such expense ratio increases were currently being controlled by expense limita- tions implemented in January 2004 and which Putnam Management, in consultation with the Contract Committee, has committed to maintain at least through 2006. The Trustees expressed their intention to monitor this information closely to ensure that fees and expenses of the Putnam funds continue to meet evolving competitive standards.
  
  
• Economies of scale. The Trustees concluded that the fee schedule currently in effect for your fund represents an appropriate sharing of economies of scale at current asset levels. Your fund currently has the benefit of breakpoints in its management fee that provide shareholders with significant economies of scale, which means that the effective management fee rate of a fund (as a percentage of fund assets) declines as a fund grows in size and crosses specified asset thresholds. The Trustees examined the existing breakpoint structure of the Putnam funds’ management fees in light of competitive industry practices. The Trustees considered various possible modifications to the Putnam Funds’ current breakpoint structure, but ulti- mately concluded that the current breakpoint structure continues to serve the interests of fund shareholders. Accordingly, the Trustees continue to believe that the fee schedules

26

currently in effect for the funds represent an appropriate sharing of economies of scale at current asset levels. The Trustees noted that significant redemptions in many Putnam funds, together with significant changes in the cost structure of Putnam Management, have altered the economics of Putnam Management’s business in significant ways. In view of these changes, the Trustees intend to consider whether a greater sharing of the economies of scale by fund shareholders would be appropriate if and when aggregate assets in the Putnam funds begin to experience meaningful growth.

In connection with their review of the management fees and total expenses of the Putnam funds, the Trustees also reviewed the costs of the services to be provided and profits to be realized by Putnam Management and its affiliates from the relationship with the funds. This information included trends in revenues, expenses and profitability of Putnam Management and its affiliates relating to the investment management and distribution services provided to the funds. In this regard, the Trustees also reviewed an analysis of Putnam Management’s revenues, expenses and profitability with respect to the funds’ management contracts, allocated on a fund-by-fund basis.

Investment performance

The quality of the investment process provided by Putnam Management represented a major factor in the Trustees’ evaluation of the quality of services provided by Putnam Management under your fund’s management contract. The Trustees were assisted in their review of the funds’ investment process and performance by the work of the Investment Oversight Committees of the Trustees, which meet on a regular monthly basis with the funds’ portfolio teams throughout the year. The Trustees concluded that Putnam Management generally provides a high quality investment process -- as measured by the experience and skills of the individuals assigned to the management of fund portfolios, the resources made available to such personnel, and in general the ability of Putnam Management to attract and retain high-quality personnel -- but also recognize that this does not guarantee favorable investment results for every fund in every time period. The Trustees considered the investment performance of each fund over multiple time periods and considered information comparing the fund’s performance with various benchmarks and with the performance of competitive funds. The Trustees noted the satisfactory investment performance of many Putnam funds. They also noted the disappointing investment performance of certain funds in recent years and continued to discuss with senior management of Putnam Management the factors contributing to such underperformance and actions being taken to improve performance. The Trustees recognized that, in recent years, Putnam Management has made significant changes in its investment personnel and processes and in the fund product line to address areas of underperformance. The Trustees indicated their intention to continue to monitor performance trends to assess the effectiveness of these changes and to evaluate whether additional remedial changes are warranted.

27

In the case of your fund, the Trustees considered that your fund’s class A share performance at net asset value was in the following percentiles of its Lipper Inc. peer group for the one-, three-and five-year periods ended December 31, 2004 (the first percentile being the best-performing funds and the 100th percentile being the worst-performing funds):

One-year period	Three-year period	Five-year period
63rd	54th	55th

(Because of the passage of time, these performance results may differ from the performance results for more recent periods shown elsewhere in this report.)

As a general matter, the Trustees believe that cooperative efforts between the Trustees and Putnam Management represent the most effective way to address investment performance problems. The Trustees believe that investors in the Putnam funds have, in effect, placed their trust in the Putnam organization, under the oversight of the funds’ Trustees, to make appropriate decisions regarding the management of the funds. Based on the responsiveness of Putnam Management in the recent past to Trustee concerns about investment performance, the Trustees believe that it is preferable to seek change within Putnam Management to address performance shortcomings. In the Trustees’ view, the alternative of terminating a management contract and engaging a new investment advisor for an underperforming fund would entail significant disruptions and would not provide any greater assurance of improved investment performance.

Brokerage and soft-dollar allocations; other benefits

The Trustees considered various potential benefits that Putnam Management may receive in connection with the services it provides under the management contract with your fund. These include principally benefits related to brokerage and soft-dollar allocations, whereby a portion of the commissions paid by a fund for brokerage is earmarked to pay for research services that may be utilized by a fund’s investment advisor. The Trustees believe that soft-dollar credits and other potential benefits associated with the allocation of fund brokerage, which pertains mainly to funds investing in equity securities, represent assets of the funds that should be used for the benefit of fund shareholders. This area has been marked by significant change in recent years. In July 2003, acting upon the Contract Committee’s recommendation, the Trustees directed that allocations of brokerage to reward firms that sell fund shares be discontinued no later than December 31, 2003. In addition, commencing in 2004, the allocation of brokerage commissions by Putnam Management to acquire research services from third-party service providers has been significantly reduced, and continues at a modest level only to acquire research that is customarily not available for cash. The Trustees will continue to monitor the allocation of the funds’ brokerage to ensure that the principle of “best price and execution” remains paramount in the portfolio trading process.

28

The Trustees’ annual review of your fund’s management contract also included the review of its distributor’s contract and distribution plan with Putnam Retail Management Limited Partnership and the custodian agreement and investor servicing agreement with Putnam Fiduciary Trust Company, all of which provide benefits to affiliates of Putnam Management.

Comparison of retail and institutional fee schedules

The information examined by the Trustees as part of their annual contract review has included for many years information regarding fees charged by Putnam Management and its affiliates to institutional clients such as defined benefit pension plans, college endowments, etc. This information included comparison of such fees with fees charged to the funds, as well as a detailed assessment of the differences in the services provided to these two types of clients. The Trustees observed, in this regard, that the differences in fee rates between institutional clients and the mutual funds are by no means uniform when examined by individual asset sectors, suggesting that differences in the pricing of investment management services to these types of clients reflect to a substantial degree historical competitive forces operating in separate market places. The Trustees considered the fact that fee rates across all asset sectors are higher on average for mutual funds than for institutional clients, as well as the differences between the services that Putnam Management provides to the Putnam funds and those that it provides to institutional clients of the firm, but have not relied on such comparisons to any significant extent in concluding that the management fees paid by your fund are reasonable.

29

Other information
for shareholders

Putnam’s policy on confidentiality

In order to conduct business with our shareholders, we must obtain certain personal information such as account holders’ addresses, telephone numbers, Social Security numbers, and the names of their financial advisors. We use this information to assign an account number and to help us maintain accurate records of transactions and account balances. It is our policy to protect the confidentiality of your information, whether or not you currently own shares of our funds, and in particular, not to sell information about you or your accounts to outside marketing firms. We have safeguards in place designed to prevent unauthorized access to our computer systems and procedures to protect personal information from unauthorized use. Under certain circumstances, we share this information with outside vendors who provide services to us, such as mailing and proxy solicitation. In those cases, the service providers enter into confidentiality agreements with us, and we provide only the information necessary to process transactions and perform other services related to your account. We may also share this information with our Putnam affiliates to service your account or provide you with information about other Putnam products or services. It is also our policy to share account information with your financial advisor, if you’ve listed one on your Putnam account. If you would like clarification about our confidentiality policies or have any questions or concerns, please don’t hesitate to contact us at 1-800-225-1581, Monday through Friday, 8:30 a.m. to 7:00 p.m., or Saturdays from 9:00 a.m. to 5:00 p.m. Eastern Time.

Proxy voting

Putnam is committed to managing our mutual funds in the best interests of our shareholders. The Putnam funds’ proxy voting guidelines and procedures, as well as information regarding how your fund voted proxies relating to portfolio securities during the 12-month period ended June 30, 2005, are available on the Putnam Individual Investor Web site, www.putnam.com/individual, and on the SEC’s Web site, www.sec.gov. If you have questions about finding forms on the SEC’s Web site, you may call the SEC at 1-800-SEC-0330. You may also obtain the Putnam funds’ proxy voting guidelines and procedures at no charge by calling Putnam’s Shareholder Services at 1-800-225-1581.

Fund portfolio holdings

The fund will file a complete schedule of its portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-Q. Shareholders may obtain the fund’s Forms N-Q on the SEC’s Web site at www.sec.gov. In addition, the fund’s Forms N-Q may be reviewed and copied at the SEC’s public reference room in Washington, D.C. You may call the SEC at 1-800-SEC-0330 for information about the SEC’s Web site or the operation of the public reference room.

30

Financial statements

A guide to financial statements

These sections of the report, as well as the accompanying Notes, preceded by the Report of Independent Registered Public Accounting Firm, constitute the fund’s financial statements.

The fund’s portfolio lists all the fund's investments and their values as of the last day of the reporting period. Holdings are organized by asset type and industry sector, country, or state to show areas of concentration and diversification.

Statement of assets and liabilities shows how the fund’s net assets and share price are determined. All investment and noninvestment assets are added together. Any unpaid expenses and other liabilities are subtracted from this total. The result is divided by the number of shares to determine the net asset value per share, which is calculated separately for each class of shares. (For funds with preferred shares, the amount subtracted from total assets includes the net assets allocated to remarketed preferred shares.)

Statement of operations shows the fund’s net investment gain or loss. This is done by first adding up all the fund’s earnings -- from dividends and interest income - -- and subtracting its operating expenses to determine net investment income (or loss). Then, any net gain or loss the fund realized on the sales of its holdings - -- as well as any unrealized gains or losses over the period -- is added to or subtracted from the net investment result to determine the fund’s net gain or loss for the fiscal year.

Statement of changes in net assets shows how the fund’s net assets were affected by the fund’s net investment gain or loss, by distributions to shareholders, and by changes in the number of the fund’s shares. It lists distributions and their sources (net investment income or realized capital gains) over the current reporting period and the most recent fiscal year-end. The distributions listed here may not match the sources listed in the Statement of operations because the distributions are determined on a tax basis and may be paid in a different period from the one in which they were earned.

Financial highlights provide an overview of the fund’s investment results, per-share distributions, expense ratios, net investment income ratios, and portfolio turnover in one summary table, reflecting the five most recent reporting periods. In a semiannual report, the highlight table also includes the current reporting period. For open-end funds, a separate table is provided for each share class.

31

Report of Independent Registered
Public Accounting Firm

To the Trustees and Shareholders of
The Putnam Fund for Growth and Income:

In our opinion, the accompanying statement of assets and liabilities, including the fund’s portfolio, and the related statements of operations and of changes in net assets and the financial highlights present fairly, in all material respects, the financial position of The Putnam Fund for Growth and Income (the “fund”) at October 31, 2005, and the results of its operations, the changes in its net assets and the financial highlights for each of the periods indicated, in conformity with accounting principles generally accepted in the United States of America. These financial statements and financial highlights (hereafter referred to as “financial statements”) are the responsibility of the fund’s management; our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits of these financial statements in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits, which included confirmation of investments owned at October 31, 2005, by correspondence with the custodian and brokers, provide a reasonable basis for our opinion.

PricewaterhouseCoopers LLP
Boston, Massachusetts
December 9, 2005

32

The fund's portfolio 10/31/05
COMMON STOCKS (99.6%)*
	Shares		Value
Aerospace and Defense (3.7%)
Boeing Co. (The)	2,115,020	$	136,714,893
Lockheed Martin Corp.	5,703,700		345,416,072
United Technologies Corp.	1,744,600		89,463,088
			571,594,053
Airlines (0.2%)
Southwest Airlines Co.	1,922,700		30,782,427
Automotive (0.1%)
Lear Corp. (S)	538,100		16,390,526
Banking (8.2%)
Bank of America Corp. (S)	13,796,400		603,454,536
Commerce Bancorp, Inc.	556,800		16,965,696
PNC Financial Services Group (S)	82,600		5,014,646
State Street Corp.	299,500		16,541,385
U.S. Bancorp	11,447,500		338,617,050
Wachovia Corp.	133,500		6,744,420
Washington Mutual, Inc.	3,040,200		120,391,920
Wells Fargo & Co. (S)	2,936,500		176,777,300
			1,284,506,953
Beverage (2.2%)
Coca-Cola Co. (The)	5,975,900		255,649,002
Coca-Cola Enterprises, Inc.	4,446,000		84,029,400
PepsiCo, Inc.	164,000		9,689,120
			349,367,522
Building Materials (1.7%)
Masco Corp.	7,053,200		201,016,200
Sherwin Williams Co.	1,424,600		60,616,730
Vulcan Materials Co.	49,900		3,243,500
			264,876,430
Cable Television (0.3%)
Comcast Corp. Class A † (S)	1,862,700		51,838,941
Chemicals (2.9%)
Dow Chemical Co. (The)	2,540,600		116,511,916
E.I. du Pont de Nemours & Co.	3,984,900		166,130,481
Hercules, Inc. †	578,600		6,445,604
Huntsman Corp. † (S)	2,605,405		51,795,451
PPG Industries, Inc.	1,100,200		65,978,994
Rohm & Haas Co.	1,085,200		47,238,756
			454,101,202

33

COMMON STOCKS (99.6%)* continued
	Shares		Value
Commercial and Consumer Services (0.9%)
ARAMARK Corp. Class B (S)	109,200	$	2,775,864
Cendant Corp.	7,774,200		135,426,564
			138,202,428
Communications Equipment (0.9%)
Cisco Systems, Inc. †	7,642,000		133,352,900
Computers (2.2%)
Hewlett-Packard Co.	11,563,200		324,232,128
IBM Corp.	175,000		14,329,000
			338,561,128
Conglomerates (5.0%)
3M Co.	885,000		67,242,300
General Electric Co.	11,001,900		373,074,429
Textron, Inc.	268,900		19,371,556
Tyco International, Ltd.	12,017,400		317,139,186
			776,827,471
Consumer Finance (2.6%)
Capital One Financial Corp.	2,538,700		193,829,745
Countrywide Financial Corp. (S)	6,727,000		213,716,790
			407,546,535
Consumer Goods (1.2%)
Avon Products, Inc. (S)	3,936,990		106,259,360
Clorox Co. (S)	56,300		3,046,956
Colgate-Palmolive Co.	92,500		4,898,800
Estee Lauder Cos., Inc. (The) Class A	1,735,100		57,553,267
Procter & Gamble Co. (The)	235,700		13,196,843
			184,955,226
Consumer Services (0.1%)
Service Corporation International	1,285,600		10,760,472
Containers (0.3%)
Owens-Illinois, Inc. †	701,540		13,357,322
Pactiv Corp. † (S)	1,438,600		28,340,420
			41,697,742
Electric Utilities (3.6%)
Dominion Resources, Inc. (S)	955,446		72,690,332
DPL, Inc.	105,900		2,729,043
Duke Energy Corp. (S)	113,300		3,000,184
Entergy Corp.	1,505,505		106,469,314
Exelon Corp. (S)	2,397,600		124,747,128
FPL Group, Inc.	435,492		18,752,286
Great Plains Energy, Inc. (S)	354,000		10,163,340
PG&E Corp. (S)	5,211,200		189,583,456

34

COMMON STOCKS (99.6%)* continued
	Shares		Value
Electric Utilities continued
Sierra Pacific Resources †	1,943,300	$	25,165,735
Wisconsin Energy Corp.	86,700		3,279,861
			556,580,679
Electronics (1.8%)
Intel Corp.	5,253,500		123,457,250
Motorola, Inc.	7,384,600		163,642,736
			287,099,986
Energy (0.6%)
Pride International, Inc. †	1,675,000		47,017,250
Weatherford International, Ltd. † (S)	667,600		41,791,760
			88,809,010
Financial (7.0%)
Citigroup, Inc.	13,513,500		618,648,029
Fannie Mae (S)	3,651,500		173,519,280
Freddie Mac	3,126,400		191,804,640
MGIC Investment Corp.	522,000		30,923,280
PMI Group, Inc. (The) (S)	1,035,400		41,291,752
Radian Group, Inc. (S)	710,000		36,991,000
			1,093,177,981
Food (0.8%)
Archer Daniels Midland Co.	115,800		2,822,046
General Mills, Inc.	531,670		25,658,394
Pilgrim's Pride Corp. (S)	71,800		2,260,264
Tyson Foods, Inc. Class A (S)	4,916,200		87,508,360
			118,249,064
Forest Products and Packaging (0.7%)
Smurfit-Stone Container Corp. † (S)	1,142,200		12,061,632
Weyerhaeuser Co.	1,584,700		100,374,898
			112,436,530
Gaming & Lottery (--%)
GTECH Holdings Corp.	120,400		3,833,536
Health Care Services (3.9%)
AmerisourceBergen Corp.	1,106,300		84,377,501
Cardinal Health, Inc.	2,687,300		167,983,123
CIGNA Corp.	1,127,700		130,666,599
Express Scripts, Inc. † (S)	794,400		59,905,704
HCA, Inc. (S)	2,146,400		103,435,016
Humana, Inc. † (S)	1,139,800		50,595,722
McKesson Corp. (S)	48,600		2,207,898
			599,171,563

35

COMMON STOCKS (99.6%)* continued
	Shares		Value
Homebuilding (0.6%)
Lennar Corp.	1,698,340	$	94,393,737
Household Furniture and Appliances (0.9%)
Whirlpool Corp. (S)	1,813,800		142,383,300
Insurance (9.1%)
ACE, Ltd. (Bermuda)	5,614,400		292,510,240
American International Group, Inc.	6,551,300		424,524,240
Axis Capital Holdings, Ltd. (Bermuda)	47,800		1,239,454
Chubb Corp. (The) (S)	2,323,500		216,015,795
Everest Re Group, Ltd. (Barbados)	358,650		35,667,743
Genworth Financial, Inc. Class A	695,430		22,038,177
Hartford Financial Services Group, Inc. (The)	1,713,500		136,651,625
MetLife, Inc.	3,236,700		159,925,347
Prudential Financial, Inc.	1,021,300		74,340,427
St. Paul Travelers Cos., Inc. (The) (S)	626,900		28,229,307
XL Capital, Ltd. Class A (Bermuda)	346,800		22,216,008
			1,413,358,363
Investment Banking/Brokerage (1.6%)
Goldman Sachs Group, Inc. (The) (S)	65,900		8,327,783
Lehman Brothers Holdings, Inc.	485,500		58,099,785
Merrill Lynch & Co., Inc.	84,500		5,470,530
Morgan Stanley	3,208,200		174,558,162
			246,456,260
Leisure (0.9%)
Brunswick Corp.	3,731,800		142,293,534
Lodging/Tourism (0.6%)
Royal Caribbean Cruises, Ltd.	2,316,900		96,012,336
Machinery (0.5%)
Parker-Hannifin Corp.	1,208,500		75,748,780
Manufacturing (0.7%)
Ingersoll-Rand Co., Ltd. Class A (Bermuda) (S)	2,802,400		105,902,696
Media (1.2%)
Time Warner, Inc.	422,000		7,524,260
Walt Disney Co. (The)	7,384,100		179,950,517
			187,474,777
Medical Technology (1.4%)
Baxter International, Inc.	2,490,000		95,192,700
Becton, Dickinson and Co.	2,225,700		112,954,275
PerkinElmer, Inc.	522,300		11,527,161
			219,674,136

36

COMMON STOCKS (99.6%)* continued
	Shares		Value
Metals (0.7%)
Alcoa, Inc.	2,952,000	$	71,704,080
United States Steel Corp. (S)	1,142,800		41,746,484
			113,450,564
Natural Gas Utilities (0.4%)
Sempra Energy	1,114,000		49,350,200
Southern Union Co. †	660,598		15,537,265
			64,887,465
Oil & Gas (9.3%)
Amerada Hess Corp. (S)	1,399,700		175,102,470
Apache Corp.	1,632,600		104,208,858
Ashland, Inc.	58,100		3,108,931
Burlington Resources, Inc.	1,525,500		110,171,610
Chevron Corp. (S)	5,100,568		291,089,416
ConocoPhillips	507,400		33,173,812
Devon Energy Corp.	1,975,800		119,298,804
Exxon Mobil Corp.	7,297,280		409,669,299
Marathon Oil Corp.	2,659,734		160,009,597
Occidental Petroleum Corp.	277,300		21,873,424
Valero Energy Corp.	202,000		21,258,480
			1,448,964,701
Pharmaceuticals (6.8%)
Abbott Laboratories	2,010,300		86,543,415
Barr Pharmaceuticals, Inc. †	365,000		20,969,250
Bristol-Myers Squibb Co.	181,100		3,833,887
Eli Lilly Co.	107,500		5,352,425
Johnson & Johnson	5,668,400		354,955,208
Mylan Laboratories, Inc.	1,053,500		20,237,735
Pfizer, Inc.	18,744,900		407,514,126
Teva Pharmaceutical Industries, Ltd. ADR (Israel) (S)	570,000		21,728,400
Wyeth	3,152,700		140,484,312
			1,061,618,758
Photography/Imaging (1.1%)
Xerox Corp. †	12,908,500		175,168,345
Publishing (0.4%)
R. R. Donnelley & Sons Co. (S)	1,911,000		66,923,220
Railroads (0.5%)
Norfolk Southern Corp.	2,083,100		83,740,620
Regional Bells (1.4%)
BellSouth Corp. (S)	153,000		3,981,060
SBC Communications, Inc.	274,500		6,546,825
Verizon Communications, Inc.	6,640,600		209,245,306
			219,773,191

37

COMMON STOCKS (99.6%)* continued
	Shares		Value
Restaurants (1.4%)
McDonald's Corp. (S)	7,045,700	$	222,644,120
Retail (4.5%)
American Eagle Outfitters, Inc.	74,500		1,754,475
Best Buy Co., Inc.	2,471,600		109,393,016
Gap, Inc. (The) (S)	3,880,000		67,046,400
Home Depot, Inc. (The)	6,273,800		257,476,752
Michaels Stores, Inc.	42,800		1,415,824
Nordstrom, Inc.	50,500		1,749,825
Office Depot, Inc. †	3,563,900		98,114,167
Rite Aid Corp. † (S)	17,586,100		61,551,350
Ross Stores, Inc.	52,000		1,406,080
Sears Holdings Corp. †	24,650		2,964,163
Supervalu, Inc.	3,045,780		95,728,865
			698,600,917
Shipping (--%)
Yellow Roadway Corp. †	78,100		3,549,645
Software (1.1%)
Oracle Corp. †	13,691,200		173,604,416
Telecommunications (0.6%)
Sprint Nextel Corp.	3,843,500		89,591,985
Tobacco (2.7%)
Altria Group, Inc.	5,538,900		415,694,445
Loews Corp. - Carolina Group	87,500		3,600,625
UST, Inc.	88,900		3,679,571
			422,974,641
Waste Management (0.3%)
Waste Management, Inc. (S)	1,646,400		48,585,264
Total common stocks (cost $12,759,449,342)		$15,532,496,076
SHORT-TERM INVESTMENTS (2.0%)*
	Principal amount/shares		Value
Short-term investments held as collateral for loaned
securities with yields ranging from 3.77% to 4.21%
and due dates ranging from November 1, 2005
to December 9, 2005 (d)	$242,351,440	$	242,290,724
Putnam Prime Money Market Fund (e)	76,304,642		76,304,642
Total short-term investments (cost $318,595,366)		$	318,595,366
TOTAL INVESTMENTS
Total investments (cost $13,078,044,708)		$15,851,091,442

38

*	Percentages indicated are based on net assets of $15,589,131,391.
†	Non-income-producing security.
(S)	Securities on loan, in part or in entirety, at October 31, 2005.
(d)	See Note 1 to the financial statements.
(e)	See Note 5 to the financial statements regarding investments in Putnam Prime Money Market Fund.
	At October 31, 2005, liquid assets totaling $5,989,763 have been designated as collateral for open written options.
	ADR after the name of a foreign holding stands for American Depository Receipts, representing ownership of foreign
	securities on deposit with a custodian bank.

WRITTEN OPTIONS OUTSTANDING at 10/31/05 (premiums received $389,679)
	Contract	Expiration date/
	amount	strike price	Value
Burlington Resources, Inc. (Put)	88,611	Nov 05 / $66.14	$ 92,368
Norfolk Southern Corp. (Call)	311,114	Nov 05 / $41.43	193,191
Total			$285,559

The accompanying notes are an integral part of these financial statements.

39

Statement of assets and liabilities 10/31/05
ASSETS
Investment in securities, at value, including $232,592,764 of securities on loan (Note 1):
Unaffiliated issuers (identified cost $13,001,740,066)	$15,774,786,800
Affiliated issuers (identified cost $76,304,642) (Note 5)	76,304,642
Dividends, interest and other receivables	10,540,736
Receivable for shares of the fund sold	3,385,353
Receivable for securities sold	79,422,837
Total assets	15,944,440,368
LIABILITIES
Payable for securities purchased	55,816,363
Payable for shares of the fund repurchased	30,094,752
Payable for compensation of Manager (Notes 2 and 5)	17,920,467
Payable for investor servicing and custodian fees (Note 2)	2,168,991
Payable for Trustee compensation and expenses (Note 2)	1,238,234
Payable for administrative services (Note 2)	13,519
Payable for distribution fees (Note 2)	4,707,770
Written options outstanding, at value (premiums received $389,679) (Note 1)	285,559
Collateral on securities loaned, at value (Note 1)	242,290,724
Other accrued expenses	772,598
Total liabilities	355,308,977
Net assets	$15,589,131,391
REPRESENTED BY
Paid-in capital (Unlimited shares authorized) (Notes 1 and 4)	$12,661,700,099
Undistributed net investment income (Note 1)	1,469,532
Accumulated net realized gain on investments
and foreign currency transactions (Note 1)	152,810,906
Net unrealized appreciation of investments	2,773,150,854
Total -- Representing net assets applicable to capital shares outstanding	$15,589,131,391
(Continued on next page)

40

Statement of assets and liabilities (Continued)
COMPUTATION OF NET ASSET VALUE AND OFFERING PRICE
Net asset value and redemption price per class A share
($11,616,126,914 divided by 598,172,559 shares)	$19.42
Offering price per class A share
(100/94.75 of $19.42)*	$20.50
Net asset value and offering price per class B share
($2,427,671,469 divided by 126,886,583 shares)**	$19.13
Net asset value and offering price per class C share
($97,924,484 divided by 5,063,079 shares)**	$19.34
Net asset value and redemption price per class M share
($123,425,468 divided by 6,398,209 shares)	$19.29
Offering price per class M share
(100/96.75 of $19.29)*	$19.94
Net asset value, offering price and redemption price per class R share
($729,159 divided by 37,654 shares)	$19.36
Net asset value, offering price and redemption price per class Y share
($1,323,253,897 divided by 67,996,420 shares)	$19.46

*	On single retail sales of less than $50,000. On sales of $50,000 or more and on group sales, the offering price is reduced.
**	Redemption price per share is equal to net asset value less any applicable contingent deferred sales charge.

The accompanying notes are an integral part of these financial statements.

41

Statement of operations Year ended October 31, 2005
INVESTMENT INCOME
Dividends (net of foreign tax of $62,041)	$ 356,999,514
Interest (including interest income of $2,238,113
from investments in affiliated issuers) (Note 5)	3,012,492
Securities lending	451,006
Other income (Note 6)	4,955,159
Total investment income	365,418,171
EXPENSES
Compensation of Manager (Note 2)	74,941,962
Investor servicing fees (Note 2)	31,755,981
Custodian fees (Note 2)	636,008
Trustee compensation and expenses (Note 2)	487,934
Administrative services (Note 2)	245,501
Distribution fees -- Class A (Note 2)	30,441,515
Distribution fees -- Class B (Note 2)	30,749,528
Distribution fees -- Class C (Note 2)	1,070,211
Distribution fees -- Class M (Note 2)	1,053,527
Distribution fees -- Class R (Note 2)	2,380
Other	1,466,015
Non-recurring costs (Notes 2 and 6)	196,475
Costs assumed by Manager (Notes 2 and 6)	(196,475)
Fees waived and reimbursed by Manager (Note 5)	(88,770)
Total expenses	172,761,792
Expense reduction (Note 2)	(4,789,128)
Net expenses	167,972,664
Net investment income	197,445,507
Net realized gain on investments (Notes 1 and 3)	1,364,188,676
Net realized loss on futures contracts (Note 1)	(61,201)
Net realized loss on foreign currency transactions (Note 1)	(2,355)
Net realized gain on written options (Notes 1 and 3)	426,758
Net unrealized depreciation of investments, futures contracts
and written options during the year	(52,404,731)
Net gain on investments	1,312,147,147
Net increase in net assets resulting from operations	$1,509,592,654

The accompanying notes are an integral part of these financial statements.

42

Statement of changes in net assets
DECREASE IN NET ASSETS
	Year ended	Year ended
	10/31/05	10/31/04
Operations:
Net investment income	$ 197,445,507	$ 207,778,733
Net realized gain on investments
and foreign currency transactions	1,364,551,878	1,054,889,728
Net unrealized appreciation (depreciation) of investments	(52,404,731)	633,890,202
Net increase in net assets resulting from operations	1,509,592,654	1,896,558,663
Distributions to shareholders: (Note 1)
From net investment income
Class A	(154,712,608)	(189,764,720)
Class B	(16,356,062)	(25,674,863)
Class C	(544,388)	(807,679)
Class M	(1,083,003)	(1,551,145)
Class R	(4,690)	(339)
Class Y	(25,339,143)	(28,138,043)
From net realized long-term gain on investments
Class A	(15,806,964)	--
Class B	(3,561,864)	--
Class C	(134,581)	--
Class M	(175,480)	--
Class R	(900)	--
Class Y	(1,833,997)	--
Redemption fees (Note 1)	34,351	40,561
Decrease from capital share transactions (Note 4)	(3,219,558,786)	(4,563,751,225)
Total decrease in net assets	(1,929,485,461)	(2,913,088,790)
NET ASSETS
Beginning of year	17,518,616,852	20,431,705,642
End of year (including undistributed net investment
income of $1,469,532 and $4,057,838, respectively)	$15,589,131,391	$17,518,616,852

The accompanying notes are an integral part of these financial statements.

43

Financial highlights (For a common share outstanding throughout the period)

CLASS A
PER-SHARE OPERATING PERFORMANCE
			Year ended
	10/31/05	10/31/04	10/31/03	10/31/02	10/31/01
Net asset value,
beginning of period	$18.07	$16.57	$13.95	$16.86	$19.81
Investment operations:
Net investment income (a)	.24(d,f )	.22(d)	.23	.22	.21
Net realized and unrealized
gain (loss) on investments	1.38	1.53	2.59	(2.60)	(2.55)
Total from
investment operations	1.62	1.75	2.82	(2.38)	(2.34)
Less distributions:
From net investment income	(.24)	(.25)	(.20)	(.21)	(.25)
From net realized gain
on investments	(.03)	--	--	(.32)	(.36)
Total distributions	(.27)	(.25)	(.20)	(.53)	(.61)
Redemption fees	--(e)	--(e)	--	--	--
Net asset value,
end of period	$19.42	$18.07	$16.57	$13.95	$16.86
Total return at
net asset value (%)(b)	8.96(f )	10.63	20.40	(14.71)	(12.15)
RATIOS AND SUPPLEMENTAL DATA
Net assets, end of period
(in thousands)	$11,616,127	$12,154,652	$14,580,763	$14,095,214	$17,731,034
Ratio of expenses to
average net assets (%)(c)	.89(d)	.92(d)	.90	.86	.82
Ratio of net investment income
to average net assets (%)	1.26(d,f )	1.25(d)	1.53	1.33	1.14
Portfolio turnover (%)	52.80	29.44	32.71	29.94	36.90

(a)	Per share net investment income has been determined on the basis of the weighted average number of shares outstanding during the period.
(b)	Total return assumes dividend reinvestment and does not reflect the effect of sales charges.
(c)	Includes amounts paid through expense offset and brokerage service arrangements (Note 2).
(d)	Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund for the periods ended October 31, 2005 and October 31, 2004 reflect a reduction of less than 0.01% of average net assets for class A shares (Note 5).
(e)	Amount represents less than $0.01 per share.
(f)	Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices, which amounted to $0.01 per share and 0.03% of average net assets for class A shares (Note 6).
	The accompanying notes are an integral part of these financial statements.

44

Financial highlights (For a common share outstanding throughout the period)

CLASS B
PER-SHARE OPERATING PERFORMANCE
			Year ended
	10/31/05	10/31/04	10/31/03	10/31/02	10/31/01
Net asset value,
beginning of period	$17.80	$16.33	$13.75	$16.62	$19.53
Investment operations:
Net investment income (a)	.10(d,f )	.09(d)	.11	.09	.07
Net realized and unrealized
gain (loss) on investments	1.35	1.50	2.56	(2.56)	(2.52)
Total from
investment operations	1.45	1.59	2.67	(2.47)	(2.45)
Less distributions:
From net investment income	(.09)	(.12)	(.09)	(.08)	(.10)
From net realized gain
on investments	(.03)	--	--	(.32)	(.36)
Total distributions	(.12)	(.12)	(.09)	(.40)	(.46)
Redemption fees	--(e)	--(e)	--	--	--
Net asset value,
end of period	$19.13	$17.80	$16.33	$13.75	$16.62
Total return at
net asset value (%)(b)	8.15(f )	9.77	19.51	(15.37)	(12.80)
RATIOS AND SUPPLEMENTAL DATA
Net assets, end of period
(in thousands)	$2,427,671	$3,364,807	$3,886,995	$4,009,396	$7,397,121
Ratio of expenses to
average net assets (%)(c)	1.64(d)	1.67(d)	1.65	1.61	1.57
Ratio of net investment income
to average net assets (%)	.55(d,f )	.50(d)	.78	.56	.39
Portfolio turnover (%)	52.80	29.44	32.71	29.94	36.90

(a)	Per share net investment income has been determined on the basis of the weighted average number of shares outstanding during the period.
(b)	Total return assumes dividend reinvestment and does not reflect the effect of sales charges.
(c)	Includes amounts paid through expense offset and brokerage service arrangements (Note 2).
(d)	Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund for the periods ended October 31, 2005 and October 31, 2004 reflect a reduction of less than 0.01% of average net assets for class B shares (Note 5).
(e)	Amount represents less than $0.01 per share.
(f)	Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices, which amounted to $0.01 per share and 0.03% of average net assets for class B shares (Note 6).
	The accompanying notes are an integral part of these financial statements.

45

Financial highlights (For a common share outstanding throughout the period)

CLASS C
PER-SHARE OPERATING PERFORMANCE
			Year ended
	10/31/05	10/31/04	10/31/03	10/31/02	10/31/01
Net asset value,
beginning of period	$17.99	$16.50	$13.90	$16.79	$19.75
Investment operations:
Net investment income (a)	.10(d,f )	.09(d)	.12	.09	.07
Net realized and unrealized
gain (loss) on investments	1.37	1.52	2.57	(2.58)	(2.55)
Total from
investment operations	1.47	1.61	2.69	(2.49)	(2.48)
Less distributions:
From net investment income	(.09)	(.12)	(.09)	(.08)	(.12)
From net realized gain
on investments	(.03)	--	--	(.32)	(.36)
Total distributions	(.12)	(.12)	(.09)	(.40)	(.48)
Redemption fees	--(e)	--(e)	--	--	--
Net asset value,
end of period	$19.34	$17.99	$16.50	$13.90	$16.79
Total return at
net asset value (%)(b)	8.18(f )	9.76	19.44	(15.30)	(12.84)
RATIOS AND SUPPLEMENTAL DATA
Net assets, end of period
(in thousands)	$97,924	$109,312	$140,116	$132,854	$168,471
Ratio of expenses to
average net assets (%)(c)	1.64(d)	1.67(d)	1.65	1.61	1.57
Ratio of net investment income
to average net assets (%)	.52(d,f )	.50(d)	.78	.57	.38
Portfolio turnover (%)	52.80	29.44	32.71	29.94	36.90

(a)	Per share net investment income has been determined on the basis of the weighted average number of shares outstanding during the period.
(b)	Total return assumes dividend reinvestment and does not reflect the effect of sales charges.
(c)	Includes amounts paid through expense offset and brokerage service arrangements (Note 2).
(d)	Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund for the periods ended October 31, 2005 and October 31, 2004 reflect a reduction of less than 0.01% of average net assets for class C shares (Note 5).
(e)	Amount represents less than $0.01 per share.
(f)	Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices, which amounted to $0.01 per share and 0.03% of average net assets for class C shares (Note 6).
	The accompanying notes are an integral part of these financial statements.

46

Financial highlights (For a common share outstanding throughout the period)

CLASS M
PER-SHARE OPERATING PERFORMANCE
			Year ended
	10/31/05	10/31/04	10/31/03	10/31/02	10/31/01
Net asset value,
beginning of period	$17.95	$16.46	$13.86	$16.75	$19.68
Investment operations:
Net investment income (a)	.15(d,f )	.13(d)	.15	.13	.12
Net realized and unrealized
gain (loss) on investments	1.36	1.52	2.58	(2.58)	(2.54)
Total from
investment operations	1.51	1.65	2.73	(2.45)	(2.42)
Less distributions:
From net investment income	(.14)	(.16)	(.13)	(.12)	(.15)
From net realized gain
on investments	(.03)	--	--	(.32)	(.36)
Total distributions	(.17)	(.16)	(.13)	(.44)	(.51)
Redemption fees	--(e)	--(e)	--	--	--
Net asset value,
end of period	$19.29	$17.95	$16.46	$13.86	$16.75
Total return at
net asset value (%)(b)	8.41(f )	10.06	19.78	(15.14)	(12.58)
RATIOS AND SUPPLEMENTAL DATA
Net assets, end of period
(in thousands)	$123,425	$145,209	$196,091	$205,097	$309,868
Ratio of expenses to
average net assets (%)(c)	1.39(d)	1.42(d)	1.40	1.36	1.32
Ratio of net investment income
to average net assets (%)	.78(d,f )	.75(d)	1.03	.82	.64
Portfolio turnover (%)	52.80	29.44	32.71	29.94	36.90

(a)	Per share net investment income has been determined on the basis of the weighted average number of shares outstanding during the period.
(b)	Total return assumes dividend reinvestment and does not reflect the effect of sales charges.
(c)	Includes amounts paid through expense offset and brokerage service arrangements (Note 2).
(d)	Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund for the periods ended October 31, 2005 and October 31, 2004 reflect a reduction of less than 0.01% of average net assets for class M shares (Note 5).
(e)	Amount represents less than $0.01 per share.
(f)	Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices, which amounted to $0.01 per share and 0.03% of average net assets for class M shares (Note 6).
	The accompanying notes are an integral part of these financial statements.

47

Financial highlights (For a common share outstanding throughout the period)

CLASS R
	PER-SHARE OPERATING PERFORMANCE
		Year ended	Year ended	Period
		10/31/05	10/31/04	1/21/03†-10/31/03
	Net asset value,
	beginning of period	$18.03	$16.58	$14.58
	Investment operations:
	Net investment income (a)	.17(d,f )	.18(d)	.15
	Net realized and unrealized
	gain on investments	1.40	1.50	1.98
	Total from
	investment operations	1.57	1.68	2.13
	Less distributions:
	From net investment income	(.21)	(.23)	(.13)
	From net realized gain
	on investments	(.03)	--	--
	Total distributions	(.24)	(.23)	(.13)
	Redemption fees	--(e)	--(e)	--
	Net asset value,
	end of period	$19.36	$18.03	$16.58
	Total return at
	net asset value (%)(b)	8.70(f )	10.20	14.71*
	RATIOS AND SUPPLEMENTAL DATA
	Net assets, end of period
	(in thousands)	$729	$191	$1
	Ratio of expenses to
	average net assets (%)(c)	1.14(d)	1.17(d)	.90*
	Ratio of net investment income
	to average net assets (%)	.90(d,f )	1.00(d)	.99*
	Portfolio turnover (%)	52.80	29.44	32.71

†	Commencement of operations.
*	Not annualized.
(a)	Per share net investment income has been determined on the basis of the weighted average number of shares outstanding during the period.
(b)	Total return assumes dividend reinvestment.
(c)	Includes amounts paid through expense offset and brokerage service arrangements (Note 2).
(d)	Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund for the periods ended October 31, 2005 and October 31, 2004 reflect a reduction of less than 0.01% of average net assets for class R shares (Note 5).
(e)	Amount represents less than $0.01 per share.
(f)	Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices, which amounted to $0.01 per share and 0.03% of average net assets for class R shares (Note 6).
	The accompanying notes are an integral part of these financial statements.

48

Financial highlights (For a common share outstanding throughout the period)

CLASS Y
PER-SHARE OPERATING PERFORMANCE
			Year ended
	10/31/05	10/31/04	10/31/03	10/31/02	10/31/01
Net asset value,
beginning of period	$18.10	$16.61	$13.98	$16.89	$19.85
Investment operations:
Net investment income (a)	.30(d,f )	.26(d)	.26	.26	.26
Net realized and unrealized
gain (loss) on investments	1.38	1.53	2.61	(2.60)	(2.56)
Total from
investment operations	1.68	1.79	2.87	(2.34)	(2.30)
Less distributions:
From net investment income	(.29)	(.30)	(.24)	(.25)	(.30)
From net realized gain
on investments	(.03)	--	--	(.32)	(.36)
Total distributions	(.32)	(.30)	(.24)	(.57)	(.66)
Redemption fees	--(e)	--(e)	--	--	--
Net asset value,
end of period	$19.46	$18.10	$16.61	$13.98	$16.89
Total return at
net asset value (%)(b)	9.28(f )	10.81	20.73	(14.46)	(11.96)
RATIOS AND SUPPLEMENTAL DATA
Net assets, end of period
(in thousands)	$1,323,254	$1,744,446	$1,627,740	$1,360,104	$1,460,710
Ratio of expenses to
average net assets (%)(c)	.64(d)	.67(d)	.65	.61	.57
Ratio of net investment income
to average net assets (%)	1.54(d,f )	1.49(d)	1.77	1.58	1.39
Portfolio turnover (%)	52.80	29.44	32.71	29.94	36.90

*	Not annualized.
(a)	Per share net investment income has been determined on the basis of the weighted average number of shares outstanding during the period.
(b)	Total return assumes dividend reinvestment.
(c)	Includes amounts paid through expense offset and brokerage service arrangements (Note 2).
(d)	Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund for the periods ended October 31, 2005 and October 31, 2004 reflect a reduction of less than 0.01% of average net assets for class Y shares (Note 5).
(e)	Amount represents less than $0.01 per share.
(f)	Reflects a non-recurring accrual related to Putnam Management’s settlement with the SEC regarding brokerage allocation practices, which amounted to $0.01 per share and 0.03% of average net assets for class Y shares (Note 6).
	The accompanying notes are an integral part of these financial statements.

49

Notes to financial statements 10/31/05

Note 1: Significant accounting policies

The Putnam Fund for Growth and Income (the “fund”), a Massachusetts business trust, is registered under the Investment Company Act of 1940, as amended, as a diversified, open-end management investment company. The fund seeks capital growth and current income by investing primarily in a portfolio of common stocks that offer the potential for capital growth, current income or both.

The fund offers class A, class B, class C, class M, class R and class Y shares. Class A and class M shares are sold with a maximum front-end sales charge of 5.25% and 3.25%, respectively, and generally do not pay a contingent deferred sales charge. Prior to April 1, 2005, the maximum front-end sales charge for class M shares was 3.50% . Class B shares, which convert to class A shares after approximately eight years, do not pay a front-end sales charge and are subject to a contingent deferred sales charge, if those shares are redeemed within six years of purchase. Class C shares are subject to the same fees as class B shares, except that class C shares have a one-year 1.00% contingent deferred sales charge and do not convert to class A shares. Class R shares, which are offered to qualified employee-benefit plans are sold without a front-end sales charge or a contingent deferred sales charge. The expenses for class A, class B, class C, class M and class R shares may differ based on the distribution fee of each class, which is identified in Note 2. Class Y shares, which are sold at net asset value, are generally subject to the same expenses as class A, class B, class C, class M and class R shares, but do not bear a distribution fee. Class Y shares are sold to certain eligible purchasers including certain defined contribution plans (including corporate IRAs), bank trust departments, trust companies, other Putnam funds and products, and certain college savings plans.

A 2.00% redemption fee may apply to any shares that are redeemed (either by selling or exchanging into another fund) within 5 days of purchase. The redemption fee is accounted for as an addition to paid-in-capital.

Investment income, realized and unrealized gains and losses and expenses of the fund are borne pro-rata based on the relative net assets of each class to the total net assets of the fund, except that each class bears expenses unique to that class (including the distribution fees applicable to such classes). Each class votes as a class only with respect to its own distribution plan or other matters on which a class vote is required by law or determined by the Trustees. Shares of each class would receive their pro-rata share of the net assets of the fund, if the fund were liquidated. In addition, the Trustees declare separate dividends on each class of shares.

In the normal course of business, the fund enters into contracts that may include agreements to indemnify another party under given circumstances. The fund’s maximum exposure under these arrangements is unknown as this would involve future claims that may be, but have not yet been, made against the fund. However, the fund expects the risk of material loss to be remote. The following is a summary of significant accounting policies consistently followed by the fund in the preparation of its financial statements. The preparation of financial statements is in conformity with accounting principles generally accepted in the United States of America and requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities in the financial statements and the reported amounts of increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates.

A) Security valuation Investments for which market quotations are readily available are valued at the last reported sales price on their principal exchange, or official closing price for certain markets. If no sales are reported -- as in the case of some securities traded over-the-counter -- a security is valued at its last reported bid price. Many securities markets and exchanges outside the U.S.

50

close prior to the close of the New York Stock Exchange and therefore the closing prices for securities in such markets or on such exchanges may not fully reflect events that occur after such close but before the close of the New York Stock Exchange. Accordingly, on certain days, the fund will fair value foreign securities taking into account multiple factors, including movements in the U.S. securities markets. The number of days on which fair value prices will be used will depend on market activity and it is possible that fair value prices will be used by the fund to a significant extent. Securities quoted in foreign currencies, if any, are translated into U.S. dollars at the current exchange rate. Short-term investments having remaining maturities of 60 days or less are valued at amortized cost, which approximates fair value. Other investments, including certain restricted securities, are valued at fair value following procedures approved by the Trustees. Such valuations and procedures are reviewed periodically by the Trustees.

B) Joint trading account Pursuant to an exemptive order from the Securities and Exchange Commission, the fund may transfer uninvested cash balances, including cash collateral received under security lending arrangements, into a joint trading account along with the cash of other registered investment companies and certain other accounts managed by Putnam Investment Management, LLC (“Putnam Management”), the fund’s manager, an indirect wholly-owned subsidiary of Putnam, LLC. These balances may be invested in issues of high-grade, short-term investments having maturities of up to 397 days for collateral received under security lending arrangements and up to 90 days for other cash investments.

C) Repurchase agreements The fund, or any joint trading account, through its custodian, receives delivery of the underlying securities, the market value of which at the time of purchase is required to be in an amount at least equal to the resale price, including accrued interest. Collateral for certain tri-party repurchase agreements is held at the counterparty’s custodian in a segregated account for the benefit of the fund and the counterparty.

Putnam Management is responsible for determining that the value of these underlying securities is at all times at least equal to the resale price, including accrued interest.

D) Security transactions and related investment income Security transactions are recorded on the trade date (date the order to buy or sell is executed). Gains or losses on securities sold are determined on the identified cost basis.

Interest income is recorded on the accrual basis. Dividend income, net of applicable withholding taxes, is recognized on the ex-dividend date except that certain dividends from foreign securities, if any, are recognized as soon as the fund is informed of the ex-dividend date. Non-cash dividends, if any, are recorded at the fair market value of the securities received.

E) Foreign currency translation The accounting records of the fund are maintained in U.S. dollars. The market value of foreign securities, currency holdings, and other assets and liabilities are recorded in the books and records of the fund after translation to U.S. dollars based on the exchange rates on that day. The cost of each security is determined using historical exchange rates. Income and withholding taxes are translated at prevailing exchange rates when earned or incurred. The fund does not isolate that portion of realized or unrealized gains or losses resulting from changes in the foreign exchange rate on investments from fluctuations arising from changes in the market prices of the securities. Such gains and losses are included with the net realized and unrealized gain or loss on investments. Net realized gains and losses on foreign currency transactions represent net realized exchange gains or losses on closed forward currency contracts, disposition of foreign currencies, currency gains and losses realized between the trade and settlement dates on securities transactions and the difference between the amount of investment income and foreign withholding taxes recorded on the fund’s books and the U.S. dollar equivalent amounts actually received or paid. Net

51

unrealized appreciation and depreciation of assets and liabilities in foreign currencies arise from changes in the value of open forward currency contracts and assets and liabilities other than investments at the period end, resulting from changes in the exchange rate. Investments in foreign securities involve certain risks, including those related to economic instability, unfavorable political developments, and currency fluctuations, not present with domestic investments.

F) Futures and options contracts The fund may use futures and options contracts to hedge against changes in the values of securities the fund owns or expects to purchase. The fund may also write options on swaps or securities it owns or in which it may invest to increase its current returns.

The potential risk to the fund is that the change in value of futures and options contracts may not correspond to the change in value of the hedged instruments. In addition, losses may arise from changes in the value of the underlying instruments, if there is an illiquid secondary market for the contracts, or if the counterparty to the contract is unable to perform. Risks may exceed amounts recognized on the statement of assets and liabilities. When the contract is closed, the fund records a realized gain or loss equal to the difference between the value of the contract at the time it was opened and the value at the time it was closed. Realized gains and losses on purchased options are included in realized gains and losses on investment securities. If a written call option is exercised, the premium originally received is recorded as an addition to sales proceeds. If a written put option is exercised, the premium originally received is recorded as a reduction to the cost of investments.

Futures contracts are valued at the quoted daily settlement prices established by the exchange on which they trade. The fund and the broker agree to exchange an amount of cash equal to the daily fluctuation in the value of the futures contract. Such receipts or payments are known as “variation margin.” Exchange traded options are valued at the last sale price, or if no sales are reported, the last bid price for purchased options and the last ask price for written options. Options traded over-the-counter are valued using prices supplied by dealers. Futures and written option contracts outstanding at period end, if any, are listed after the fund’s portfolio.

G) Security lending The fund may lend securities, through its agents, to qualified borrowers in order to earn additional income. The loans are collateralized by cash and/or securities in an amount at least equal to the market value of the securities loaned. The market value of securities loaned is determined daily and any additional required collateral is allocated to the fund on the next business day. The risk of borrower default will be borne by the fund’s agents; the fund will bear the risk of loss with respect to the investment of the cash collateral. Income from securities lending is included in investment income on the statement of operations. At October 31, 2005, the value of securities loaned amounted to $232,592,764. The fund received cash collateral of $242,290,724, which is pooled with collateral of other Putnam funds into 16 issues of high-grade, short-term investments.

H) Federal taxes It is the policy of the fund to distribute all of its taxable income within the prescribed time and otherwise comply with the provisions of the Internal Revenue Code of 1986 (the “Code”) applicable to regulated investment companies. It is also the intention of the fund to distribute an amount sufficient to avoid imposition of any excise tax under Section 4982 of the Code, as amended. Therefore, no provision has been made for federal taxes on income, capital gains or unrealized appreciation on securities held nor for excise tax on income and capital gains.

I) Distributions to shareholders Distributions to shareholders from net investment income are recorded by the fund on the ex-dividend date. Distributions from capital gains, if any, are recorded on the ex-dividend date and paid at least annually. The amount and character of income and gains to be distributed are determined in accordance with income tax regulations, which may differ from generally accepted accounting principles. These

52

differences include temporary and permanent differences of losses on wash sale transactions, foreign currency gains and losses, nontaxable dividends and realized gains and losses on certain futures contracts. Reclassifications are made to the fund’s capital accounts to reflect income and gains available for distribution (or available capital loss carryovers) under income tax regulations. For the year ended October 31, 2005, the fund reclassified $1,993,919 to decrease undistributed net investment income with an increase to accumulated net realized gain of $ 1,993,919.

The tax basis components of distributable earnings and the federal tax cost as of period end were as follows:

Unrealized appreciation	$ 3,165,247,855
Unrealized depreciation	(554,679,810)
	-------------------------------
Net unrealized appreciation	2,610,568,045
Undistributed long term gain	316,759,126
Cost for federal income
tax purposes	$13,240,523,397

Note 2: Management fee, administrative
services and other transactions

Putnam Management is paid for management and investment advisory services quarterly based on the average net assets of the fund. Such fee is based on the following annual rates: 0.65% of the first $500 million of average net assets, 0.55% of the next $500 million, 0.50% of the next $500 million, 0.45% of the next $5 billion, 0.425% of the next $5 billion, 0.405% of the next $5 billion, 0.39% of the next $5 billion, 0.38% of the next $5 billion, 0.37% of the next $5 billion, 0.36% of the next $5 billion, 0.35% of the next $5 billion, 0.34% of the next $5 billion, 0.33% of the next $8.5 billion and 0.32% thereafter.

Putnam Management has agreed to waive fees and reimburse expenses of the fund through October 31, 2006, to the extent necessary to ensure that the fund’s expenses do not exceed the simple average of the expenses of all front-end load funds viewed by Lipper Inc. as having the same investment classification or objective as the fund. The expense reimbursement is based on a comparison of the fund’s expenses with the average annualized operating expenses of the funds in its Lipper peer group for each calendar quarter during the fund’s last fiscal year, excluding 12b-1 fees and without giving effect to any expense offset and brokerage service arrangements that may reduce fund expenses. For the year ended October 31, 2005, Putnam Management did not waive any of its management fee from the fund.

For the year ended October 31, 2005, Putnam Management has assumed $196,475 of legal, shareholder servicing and communication, audit and Trustee fees incurred by the fund in connection with certain legal and regulatory matters (including those described in Note 6).

The fund reimburses Putnam Management an allocated amount for the compensation and related expenses of certain officers of the fund and their staff who provide administrative services to the fund. The aggregate amount of all such reimbursements is determined annually by the Trustees.

Custodial functions for the fund’s assets are provided by Putnam Fiduciary Trust Company (“PFTC”), a subsidiary of Putnam, LLC. PFTC receives fees for custody services based on the fund’s asset level, the number of its security holdings and transaction volumes. Putnam Investor Services, a division of PFTC, provides investor servicing agent functions to the fund. Putnam Investor Services receives fees for investor servicing based on the number of shareholder accounts in the fund and the level of defined contribution plan assets in the fund. During the year ended October 31, 2005, the fund paid PFTC $32,383,784 for these services.

The fund has entered into an arrangement with PFTC whereby credits realized as a result of uninvested cash balances are used to reduce a portion of the fund’s expenses. The fund also reduced expenses through brokerage service arrangements. For the year ended October 31, 2005, the fund’s expenses were reduced by $4,789,128 under these arrangements.

53

Each independent Trustee of the fund receives an annual Trustee fee, of which $2,974, as a quarterly retainer, has been allocated to the fund, and an additional fee for each Trustees meeting attended. Trustees receive additional fees for attendance at certain committee meetings, industry seminars and for certain compliance-related matters. Trustees also are reimbursed for expenses they incur relating to their services as Trustees. George Putnam, III, who is not an independent Trustee, also receives the foregoing fees for his services as Trustee.

The fund has adopted a Trustee Fee Deferral Plan (the “Deferral Plan”) which allows the Trustees to defer the receipt of all or a portion of Trustees fees payable on or after July 1, 1995. The deferred fees remain invested in certain Putnam funds until distribution in accordance with the Deferral Plan.

The fund has adopted an unfunded noncontributory defined benefit pension plan (the “Pension Plan”) covering all Trustees of the fund who have served as a Trustee for at least five years and were first elected prior to 2004. Benefits under the Pension Plan are equal to 50% of the Trustee’s average total retainer and meeting fees for the three years preceding retirement. Pension expense for the fund is included in Trustee compensation and expenses in the statement of operations. Accrued pension liability is included in Payable for Trustee compensation and expenses in the statement of assets and liabilities. The Trustees have terminated the Pension Plan with respect to any Trustee first elected after 2003.

The fund has adopted distribution plans (the “Plans”) with respect to its class A, class B, class C, class M and class R shares pursuant to Rule 12b-1 under the Investment Company Act of 1940. The purpose of the Plans is to compensate Putnam Retail Management, a wholly-owned subsidiary of Putnam, LLC and Putnam Retail Management GP, Inc., for services provided and expenses incurred in distributing shares of the fund. The Plans provide for payments by the fund to Putnam Retail Management at an annual rate of up to 0.35%, 1.00%, 1.00%, 1.00% and 1.00% of the average net assets attributable to class A, class B, 54 class C, class M and class R shares, respectively.  The Trustees have approved payment by the fund at an annual rate of 0.25%, 1.00%, 1.00%, 0.75% and 0.50% of the average net assets attributable to class A, class B, class C, class M and class R shares, respectively.

For the year ended October 31, 2005, Putnam Retail Management, acting as underwriter, received net commissions of $423,856 and $5,899 from the sale of class A and class M shares, respectively, and received $2,967,748 and $6,800 in contingent deferred sales charges from redemptions of class B and class C shares, respectively. A deferred sales charge of up to 1.00% and 0.65% is assessed on certain redemptions of class A and class M shares, respectively. For the year ended October 31, 2005, Putnam Retail Management, acting as underwriter, received $8,700 and no monies on class A and class M redemptions, respectively.

Note 3: Purchases and sales of securities

During the year ended October 31, 2005, cost of purchases and proceeds from sales of investment securities other than short-term investments aggregated $8,950,904,703 and $12,176,493,391, respectively. There were no purchases or sales of U.S. government securities.

Written option transactions during the year are summarized as follows:

	Contract		Premiums
	Amounts		Received
Written options
outstanding at
beginning of year	115,811	$	237,517
Options opened	707,602		811,428
Options exercised	(193,904)		(226,810)
Options expired	(115,811)		(237,517)
Options closed	(113,973)		(194,939)
Written options
outstanding at
end of year	399,725	$	389,679

Note 4: Capital shares

At October 31, 2005, there was an unlimited number of shares of beneficial interest authorized. Transactions in capital shares were as follows:

CLASS A	Shares	Amount
Year ended 10/31/05:
Shares sold	61,879,373	$ 1,191,574,589
Shares issued
in connection
with reinvestment
of distributions	8,081,523	157,085,106
	69,960,896	1,348,659,695
Shares
repurchased	(144,549,010)	(2,785,662,373)
Net decrease	(74,588,114)	$(1,437,002,678)
Year ended 10/31/04:
Shares sold	46,845,463	$ 829,959,093
Shares issued
in connection
with reinvestment
of distributions	9,935,249	174,971,459
	56,780,712	1,004,930,552
Shares
repurchased	(263,743,238)	(4,595,324,686)
Net decrease	(206,962,526)	$(3,590,394,134)
CLASS B	Shares	Amount
Year ended 10/31/05:
Shares sold	7,301,432	$ 138,079,476
Shares issued
in connection
with reinvestment
of distributions	980,648	18,709,707
	8,282,080	156,789,183
Shares
repurchased	(70,439,851)	(1,337,148,136)
Net decrease	(62,157,771)	$(1,180,358,953)
Year ended 10/31/04:
Shares sold	13,306,158	$ 231,906,748
Shares issued
in connection
with reinvestment
of distributions	1,401,696	23,984,808
	14,707,854	255,891,556
Shares
repurchased	(63,646,331)	(1,094,161,154)
Net decrease	(48,938,477)	$ (838,269,598)

CLASS C	Shares	Amount
Year ended 10/31/05:
Shares sold	688,876	$ 13,195,853
Shares issued
in connection
with reinvestment
of distributions	31,863	615,205
	720,739	13,811,058
Shares
repurchased	(1,733,028)	(33,275,840)
Net decrease	(1,012,289)	$(19,464,782)
Year ended 10/31/04:
Shares sold	980,495	$ 17,366,483
Shares issued
in connection
with reinvestment
of distributions	42,398	732,592
	1,022,893	18,099,075
Shares
repurchased	(3,437,566)	(59,531,393)
Net decrease	(2,414,673)	$(41,432,318)
CLASS M	Shares	Amount
Year ended 10/31/05:
Shares sold	593,514	$ 11,301,717
Shares issued
in connection
with reinvestment
of distributions	62,781	1,210,245
	656,295	12,511,962
Shares
repurchased	(2,349,318)	(45,121,183)
Net decrease	(1,693,023)	$(32,609,221)
Year ended 10/31/04:
Shares sold	889,399	$ 15,627,876
Shares issued
in connection
with reinvestment
of distributions	85,513	1,482,523
	974,912	17,110,399
Shares
repurchased	(4,795,920)	(83,269,898)
Net decrease	(3,821,008)	$(66,159,499)

55

CLASS R	Shares	Amount
Year ended 10/31/05:
Shares sold	29,709	$571,862
Shares issued
in connection
with reinvestment
of distributions	287	5,590
	29,996	577,452
Shares
repurchased	(2,961)	(57,217)
Net increase	27,035	$520,235
Year ended 10/31/04:
Shares sold	10,660	$190,786
Shares issued
in connection
with reinvestment
of distributions	19	339
	10,679	191,125
Shares
repurchased	(129)	(2,295)
Net increase	10,550	$188,830
CLASS Y	Shares	Amount
Year ended 10/31/05:
Shares sold	18,152,973	$ 350,212,284
Shares issued
in connection
with reinvestment
of distributions	1,396,645	27,173,140
	19,549,618	377,385,424
Shares
repurchased	(47,909,086)	(928,028,811)
Net decrease	(28,359,468)	$(550,643,387)
Year ended 10/31/04:
Shares sold	25,697,636	$ 457,615,976
Shares issued
in connection
with reinvestment
of distributions	1,589,397	28,138,043
	27,287,033	485,754,019
Shares
repurchased	(28,951,932)	(513,438,525)
Net decrease	(1,664,899)	$ (27,684,506)

Note 5: Investment in Putnam
Prime Money Market Fund

Pursuant to an exemptive order from the Securities and Exchange Commission, the fund invests in Putnam Prime Money Market Fund, an open-end management investment company managed by Putnam Management. Management fees paid by the fund are reduced by an amount equal to the management and administrative services fees paid by Putnam Prime Money Market Fund with respect to assets invested by the fund in Putnam Prime Money Market Fund. For the year ended October 31, 2005, management fees paid were reduced by $88,770 relating to the fund’s investment in Putnam Prime Money Market Fund. Income distributions earned by the fund are recorded as income in the statement of operations and totaled $2,238,113 for the year ended October 31, 2005. During the year ended October 31, 2005, cost of purchases and cost of sales of investments in Putnam Prime Money Market Fund aggregated $2,362,032,028 and $2,357,461,347, respectively.

Note 6: Regulatory matters and litigation

Putnam Management has entered into agreements with the Securities and Exchange Commission and the Massachusetts Securities Division settling charges connected with excessive short-term trading by Putnam employees and, in the case of the charges brought by the Massachusetts Securities Division, by participants in some Putnam-administered 401(k) plans. Pursuant to these settlement agreements, Putnam Management will pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders and the funds. The amount will be allocated to shareholders and funds pursuant to a plan developed by an independent consultant, and will be paid following approval of the plan by the SEC and the Massachusetts Securities Division.

The Securities and Exchange Commission’s and Massachusetts Securities Division’s allegations and

56

related matters also serve as the general basis for numerous lawsuits, including purported class action lawsuits filed against Putnam Management and certain related parties, including certain Putnam funds. Putnam Management will bear any costs incurred by Putnam funds in connection with these lawsuits. Putnam Management believes that the likelihood that the pending private lawsuits and purported class action lawsuits will have a material adverse financial impact on the fund is remote, and the pending actions are not likely to materially affect its ability to provide investment management services to its clients, including the Putnam funds.

On March 23, 2005, Putnam Management entered into a settlement with the Securities and Exchange Commission resolving its inquiry into Putnam Management’s alleged failure to fully and effectively disclose a former brokerage allocation practice to the Board of Trustees and shareholders of the Putnam Funds. This practice, which Putnam Management ceased as of January 1, 2004, involved allocating a portion of the brokerage on mutual fund portfolio transactions to certain broker-dealers who sold shares of Putnam mutual funds. Under the settlement order, Putnam Management has paid a civil penalty of $40 million and disgorgement of $1 to the Securities and Exchange Commission. Of these amounts, $4,955,159 was distributed to the fund pursuant to a plan approved by the Securities and Exchange Commission and is included in Other income on the Statement of operations. As part of the settlement, Putnam Management neither admitted nor denied any wrongdoing.

Putnam Investments has recorded a charge of $30 million for the estimated cost, excluding interest, that it believes will be necessary to address issues relating to the calculation of certain amounts paid by the Putnam mutual funds in previous years. The previous payments were cost reimbursements by the Putnam funds to Putnam for transfer agent services relating to defined contribution operations. Putnam currently anticipates that any payments made by Putnam related to this issue will be paid to the Putnam funds. Review of this issue is ongoing.

Putnam Management and Putnam Retail Management are named as defendants in a civil suit in which the plaintiffs allege that the management and distribution fees paid by certain Putnam funds were excessive and seek recovery under the Investment Company Act of 1940. Putnam Management and Putnam Retail Management have contested the plaintiffs’ claims and the matter is currently pending in the U.S. District Court for the District of Massachusetts. Based on currently available information, Putnam Management believes that this action is without merit and that it is unlikely to have a material effect on Putnam Management’s and Putnam Retail Management’s ability to provide services to their clients, including the fund.

57

Federal tax information
(Unaudited)

Pursuant to Section 852 of the Internal Revenue Code, as amended, the fund hereby designates $338,272,912 as long-term capital gain, for its taxable year ended October 31, 2005.

The fund designated 100% of ordinary income distributions as qualifying for the dividends received deduction for corporations.

For its tax year ended October 31, 2005, the fund hereby designates 100%, or the maximum amount allowable, of its taxable ordinary income distributions as qualified dividends taxed at the individual net capital gain rates.

The Form 1099 you receive in January 2006 will show the tax status of all distributions paid to your account in calendar 2005.

58

Brokerage commissions
(Unaudited)

Brokerage commissions are paid to firms that execute trades on behalf of your fund. When choosing these firms, Putnam is required by law to seek the best execution of the trades, taking all relevant factors into consideration, including expected quality of execution and commission rate. Listed below are the largest relationships based upon brokerage commissions for your fund and the other funds in Putnam’s Large-Cap Value group for the year ended October 31, 2005. The other Putnam mutual funds in this group are The George Putnam Fund of Boston, Putnam Classic Equity Fund, Putnam Convertible Income-Growth Trust, Putnam Equity Income Fund, Putnam New Value Fund, Putnam VT Equity Income Fund, Putnam VT The George Putnam Fund of Boston, Putnam VT Growth and Income Fund, and Putnam VT New Value Fund.

The top five firms that received brokerage commissions for trades executed for the Large-Cap Value group are (in descending order) Goldman Sachs, Citigroup Global Markets, Deutsche Bank Securities, Lehman Brothers, and Merrill Lynch. Commissions paid to these firms together represented approximately 48% of the total brokerage commissions paid for the year ended October 31, 2005.

Commissions paid to the next 10 firms together represented approximately 36% of the total brokerage commissions paid during the period. These firms are (in alphabetical order) Bank of America, Bear Stearns & Company, CIBC World Markets, Credit Suisse First Boston, JP Morgan Clearing, Lazard Freres & Co., Morgan Stanley Dean Witter, RBC Capital Markets, UBS Warburg, and Wachovia Securities.

Commission amounts do not include “mark-ups” paid on bond or derivative trades made directly with a dealer. Additional information about brokerage commissions is available on the Securities and Exchange Commission (SEC) Web site at www.sec.gov. Putnam funds disclose commissions by firm to the SEC in semiannual filings on Form N-SAR.

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About the Trustees

Jameson A. Baxter (Born 1943), Trustee since 1994, Vice Chairman since 2005

Ms. Baxter is the President of Baxter Associates, Inc., a private investment firm that she founded in 1986.

Ms. Baxter serves as a Director of ASHTA Chemicals, Inc., Banta Corporation (a printing and digital imaging firm), Ryerson Tull, Inc. (a steel service corporation), the Mutual Fund Directors Forum, Advocate Health Care and BoardSource, formerly the National Center for Nonprofit Boards. She is Chairman Emeritus of the Board of Trustees, Mount Holyoke College, having served as Chairman for five years and as a board member for thirteen years. Until 2002, Ms. Baxter was a Director of Intermatic Corporation (a manufacturer of energy control products).

Ms. Baxter has held various positions in investment banking and corporate finance, including Vice President and Principal of the Regency Group, and Vice President of and Consultant to First Boston Corporation. She is a graduate of Mount Holyoke College.

Charles B. Curtis (Born 1940), Trustee since 2001

Mr. Curtis is President and Chief Operating Officer of the Nuclear Threat Initiative (a private foundation dealing with national security issues) and serves as Senior Advisor to the United Nations Foundation.

Mr. Curtis is a member of the Council on Foreign Relations and the Trustee Advisory Council of the Applied Physics Laboratory, Johns Hopkins University. Until 2003, Mr. Curtis was a member of the Electric Power Research Institute Advisory Council and the University of Chicago Board of Governors for Argonne National Laboratory. Prior to 2002, Mr. Curtis was a Member of the Board of Directors of the Gas Technology Institute and the Board of Directors of the Environment and Natural Resources Program Steering Committee, John F. Kennedy School of Government, Harvard University. Until 2001, Mr. Curtis was a member of the Department of Defense Policy Board and Director of EG&G Technical Services, Inc. (a fossil energy research and development support company).

From August 1997 to December 1999, Mr. Curtis was a Partner at Hogan & Hartson L.L.P., a Washington, D.C. law firm. Prior to May 1997, Mr. Curtis was Deputy Secretary of Energy. He served as Chairman of the Federal Energy Regulatory Commission from 1977 to 1981 and has held positions on the staff of the U.S. House of Representatives, the U.S. Treasury Department, and the SEC.

60

Myra R. Drucker (Born 1948), Trustee since 2004

Ms. Drucker is a Vice Chair of the Board of Trustees of Sarah Lawrence College, a Trustee of Commonfund (a not-for-profit firm specializing in asset management for educational endowments and foundations) and a member of the Investment Committee of the Kresge Foundation (a charitable trust).

Ms. Drucker is an ex-officio member of the New York Stock Exchange (NYSE) Pension Managers Advisory Committee, having served as Chair for seven years and a member of the Executive Committee of the Committee on Investment of Employee Benefit Assets. She is Chair of the Advisory Board of Hamilton Lane Advisors (an investment management firm) and a member of the Advisory Board of RCM (an investment management firm). Until August 31, 2004, Ms. Drucker was Managing Director and a member of the Board of Directors of General Motors Asset Management and Chief Investment Officer of General Motors Trust Bank. Ms. Drucker also served as a member of the NYSE Corporate Accountability and Listing Standards Committee and the NYSE/NASD IPO Advisory Committee.

Prior to joining General Motors Asset Management in 2001, Ms. Drucker held various executive positions in the investment management industry. Ms. Drucker served as Chief Investment Officer of Xerox Corporation (a technology and service company in the document industry), where she was responsible for the investment of the company’s pension assets. Ms. Drucker was also Staff Vice President and Director of Trust Investments for International Paper (a paper, paper distribution, packaging and forest products company) and previously served as Manager of Trust Investments for Xerox Corporation. Ms. Drucker received a B.A. degree in Literature and Psychology from Sarah Lawrence College and pursued graduate studies in economics, statistics and portfolio theory at Temple University.

John A. Hill (Born 1942), Trustee since 1985 and Chairman since 2000

Mr. Hill is Vice Chairman of First Reserve Corporation, a private equity buyout firm that specializes in energy investments in the diversified worldwide energy industry.

Mr. Hill is a Director of Devon Energy Corporation, TransMontaigne Oil Company and various private companies controlled by First Reserve Corporation, as well as Chairman of TH Lee, Putnam Investment Trust (a closed-end investment company advised by an affiliate of Putnam Management). He is also a Trustee of Sarah Lawrence College. Until 2005, he was a Director of Continuum Health Partners of New York.

Prior to acquiring First Reserve Corporation in 1983, Mr. Hill held executive positions in investment banking and investment management with several firms and with the federal government, including Deputy Associate Director of the Office of Management and Budget and Deputy

61

Director of the Federal Energy Administration. He is active in various business associations, including the Economic Club of New York, and lectures on energy issues in the United States and Europe. Mr. Hill holds a B.A. degree in Economics from Southern Methodist University and pursued graduate studies there as a Woodrow Wilson Fellow.

Paul L. Joskow (Born 1947), Trustee since 1997

Dr. Joskow is the Elizabeth and James Killian Professor of Economics and Management, and Director of the Center for Energy and Environmental Policy Research at the Massachusetts Institute of Technology.

Dr. Joskow serves as a Director of National Grid plc (a UK-based holding company with interests in electric and gas transmission and distribution and telecommunications infrastructure) and TransCanada Corporation (an energy company focused on natural gas transmission and power services). He also serves on the Board of Overseers of the Boston Symphony Orchestra. Prior to February 2005, he served on the board of the Whitehead Institute for Biomedical Research (a non-profit research institution) and has been President of the Yale University Council since 1993. Prior to February 2002, he was a Director of State Farm Indemnity Company (an automobile insurance company), and, prior to March 2000, he was a Director of New England Electric System (a public utility holding company).

Dr. Joskow has published five books and numerous articles on topics in industrial organization, government regulation of industry, and competition policy. He is active in industry restructuring, environmental, energy, competition and privatization policies -- serving as an advisor to governments and corporations worldwide. Dr. Joskow holds a Ph.D. and M. Phil from Yale University and a B.A. from Cornell University.

Elizabeth T. Kennan (Born 1938), Trustee since 1992

Dr. Kennan is a Partner of Cambus-Kenneth Farm (thoroughbred horse and cattle breeding). She is President Emeritus of Mount Holyoke College.

Dr. Kennan served as Chairman and is now Lead Director of Northeast Utilities. Until 2005, she was a Director of Talbots, Inc. She has served as Director on a number of other boards, including Bell Atlantic, Chastain Real Estate, Shawmut Bank, Berkshire Life Insurance and Kentucky Home Life Insurance. She is a Trustee of the National Trust for Historic Preservation, of Centre College and of Midway College in Midway, Kentucky. She is also a member of The Trustees of Reservations. Dr. Kennan has served on the oversight committee of the Folger Shakespeare Library, as President of Five Colleges Incorporated, as a Trustee of Notre Dame University and is active in various educational and civic associations.

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As a member of the faculty of Catholic University for twelve years, until 1978, Dr. Kennan directed the post-doctoral program in Patristic and Medieval Studies, taught history and published numerous articles. Dr. Kennan holds a Ph.D. from the University of Washington in Seattle, an M.S. from St. Hilda’s College at Oxford University and an A.B. from Mount Holyoke College. She holds several honorary doctorates.

John H. Mullin, III (Born 1941), Trustee since 1997

Mr. Mullin is the Chairman and CEO of Ridgeway Farm (a limited liability company engaged in timber and farming).

Mr. Mullin serves as a Director of The Liberty Corporation (a broadcasting company), Progress Energy, Inc. (a utility company, formerly known as Carolina Power & Light) and Sonoco Products, Inc. (a packaging company). Mr. Mullin is Trustee Emeritus of The National Humanities Center and Washington & Lee University, where he served as Chairman of the Investment Committee. Prior to May 2001, he was a Director of Graphic Packaging International Corp. Prior to February 2004, he was a Director of Alex Brown Realty, Inc.

Mr. Mullin is also a past Director of Adolph Coors Company; ACX Technologies, Inc.; Crystal Brands, Inc.; Dillon, Read & Co., Inc.; Fisher-Price, Inc.; and The Ryland Group, Inc. Mr. Mullin is a graduate of Washington & Lee University and The Wharton Graduate School, University of Pennsylvania.

Robert E. Patterson (Born 1945), Trustee since 1984

Mr. Patterson is Senior Partner of Cabot Properties, L.P. and Chairman of Cabot Properties, Inc. (a private equity firm investing in commercial real estate).

Mr. Patterson serves as Chairman Emeritus and Trustee of the Joslin Diabetes Center and as a Director of Brandywine Trust Group, LLC. Prior to June 2003, he was a Trustee of Sea Education Association. Prior to December 2001, he was President and Trustee of Cabot Industrial Trust (a publicly traded real estate investment trust). Prior to February 1998, he was Executive Vice President and Director of Acquisitions of Cabot Partners Limited Partnership (a registered investment adviser involved in institutional real estate investments). Prior to 1990, he served as Executive Vice President of Cabot, Cabot & Forbes Realty Advisors, Inc. (the predecessor company of Cabot Partners).

Mr. Patterson practiced law and held various positions in state government and was the founding Executive Director of the Massachusetts Industrial Finance Agency. Mr. Patterson is a graduate of Harvard College and Harvard Law School.

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W. Thomas Stephens (Born 1942), Trustee since 1997

Mr. Stephens is Chairman and Chief Executive Officer of Boise Cascade, L.L.C. (a paper, forest products and timberland assets company).

Until 2004, Mr. Stephens was a Director of Xcel Energy Incorporated (a public utility company), Qwest Communications, and Norske Canada, Inc. (a paper manufacturer). Until 2003, Mr. Stephens was a Director of Mail-Well, Inc. (a diversified printing company). He served as Chairman of Mail-Well until 2001 and as CEO of MacMillan-Bloedel, Ltd. (a forest products company) until 1999.

Prior to 1996, Mr. Stephens was Chairman and Chief Executive Officer of Johns Manville Corporation. He holds B.S. and M.S. degrees from the University of Arkansas.

Richard B. Worley (Born 1945), Trustee since 2004

Mr. Worley is Managing Partner of Permit Capital LLC, an investment management firm.

Mr. Worley serves on the Executive Committee of the University of Pennsylvania Medical Center, is a Trustee of The Robert Wood Johnson Foundation (a philanthropic organization devoted to health care issues) and is a Director of The Colonial Williamsburg Foundation (a historical preservation organization). Mr. Worley also serves on the investment committees of Mount Holyoke College and World Wildlife Fund (a wildlife conservation organization).

Prior to joining Permit Capital LLC in 2002, Mr. Worley served as Chief Strategic Officer of Morgan Stanley Investment Management. He previously served as President, Chief Executive Officer and Chief Investment Officer of Morgan Stanley Dean Witter Investment Management and as a Managing Director of Morgan Stanley, a financial services firm. Mr. Worley also was the Chairman of Miller Anderson & Sherrerd, an investment management firm.

Mr. Worley holds a B.S. degree from University of Tennessee and pursued graduate studies in economics at the University of Texas.

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Charles E. Haldeman, Jr.* (Born 1948), Trustee since 2004 

Mr. Haldeman is President and Chief Executive Officer of Putnam, LLC (“Putnam Investments”). 

He is a member of Putnam Investments’ Executive Board of Directors and Advisory Council. 

Prior to November 2003, Mr. Haldeman served as Co-Head of Putnam Investments’ 

Investment Division. 

Prior to joining Putnam Investments in 2002, Mr. Haldeman held executive positions in the invest- 

ment management industry. He previously served as Chief Executive Officer of Delaware 

Investments and President & Chief Operating Officer of United Asset Management. Mr. Haldeman 

was also a partner and director of Cooke & Bieler, Inc. (an investment management firm). 

Mr. Haldeman currently serves as a Trustee of Dartmouth College and is a member of the 

Partners HealthCare Systems Investment Committee. He is a graduate of Dartmouth College, 

Harvard Law School and Harvard Business School. Mr. Haldeman is also a Chartered Financial 

Analyst (CFA) charterholder. 

George Putnam, III* (Born 1951), Trustee since 1984 and President since 2000 

Mr. Putnam is President of New Generation Research, Inc. (a publisher of financial advisory and 

other research services), and of New Generation Advisers, Inc. (a registered investment 

advisor to private funds). Mr. Putnam founded the New Generation companies in 1986. 

Mr. Putnam is a Director of The Boston Family Office, LLC (a registered investment adviser). 

He is a Trustee of St. Mark’s School and Shore Country Day School, and until 2002 was a 

Trustee of the Sea Education Association. 

Mr. Putnam previously worked as an attorney with the law firm of Dechert LLP (formerly 

known as Dechert Price & Rhoads) in Philadelphia. He is a graduate of Harvard College, 

Harvard Business School and Harvard Law School. 

	The address of each Trustee is One Post Office Square, Boston, MA 02109.
	As of October 31, 2005, there were 108 Putnam Funds. All Trustees serve as Trustees of all Putnam funds. Each Trustee serves for an indefinite term, until his or her resignation, retirement at age 72, death, or removal.
*	Trustees who are or may be deemed to be “interested persons” (as defined in the Investment Company Act of 1940) of the fund, Putnam Management, Putnam Retail Management, or Marsh & McLennan Companies, Inc., the parent company of Putnam, LLC and its affiliated companies. Messrs. Haldeman and Putnam, III are deemed “interested persons” by virtue of their positions as officers of the fund, Putnam Management or Putnam Retail Management and as shareholders of Marsh & McLennan Companies, Inc. Mr. Putnam, III is the President of your fund and each of the other Putnam funds. Mr. Haldeman is President and Chief Executive Officer of Putnam Investments.

65

Officers

In addition to George Putnam, III, the other officers of the fund are shown below:

Charles E. Porter (Born 1938) 

Executive Vice President, Associate Treasurer 

and Principal Executive Officer 

Since 1989 

Jonathan S. Horwitz (Born 1955) 

Senior Vice President and Treasurer 

Since 2004 

Prior to 2004, Managing Director, 

Putnam Investments 

Steven D. Krichmar (Born 1958) 

Vice President and Principal Financial Officer 

Since 2002 

Senior Managing Director, Putnam 

Investments. Prior to July 2001, Partner, 

PricewaterhouseCoopers LLP 

Michael T. Healy (Born 1958) 

Assistant Treasurer and Principal 

Accounting Officer 

Since 2000 

Managing Director, Putnam Investments 

Beth S. Mazor (Born 1958) 

Vice President 

Since 2002 

Senior Vice President, Putnam Investments 

Daniel T. Gallagher (Born 1962) 

Senior Vice President, Staff Counsel 

and Compliance Liaison 

Since 2004 

Prior to 2004, Associate, Ropes & Gray LLP; 

prior to 2000, Law Clerk, Massachusetts 

Supreme Judicial Court 

Francis J. McNamara, III (Born 1955) 

Vice President and Chief Legal Officer 

Since 2004 

Senior Managing Director, Putnam 

Investments, Putnam Management 

and Putnam Retail Management. Prior 

to 2004, General Counsel, State Street 

Research & Management Company 

James P. Pappas (Born 1953) 

Vice President 

Since 2004 

Managing Director, Putnam Investments 

and Putnam Management. During 2002, 

Chief Operating Officer, Atalanta/Sosnoff 

Management Corporation; prior to 2001, 

President and Chief Executive Officer, 

UAM Investment Services, Inc. 

Richard S. Robie, III (Born 1960) 

Vice President 

Since 2004 

Senior Managing Director, Putnam 

Investments, Putnam Management 

and Putnam Retail Management. Prior 

to 2003, Senior Vice President, United 

Asset Management Corporation 

Charles A. Ruys de Perez (Born 1957) 

Vice President and Chief Compliance Officer 

Since 2004 

Managing Director, Putnam Investments 

Mark C. Trenchard (Born 1962) 

Vice President and BSA Compliance Officer 

Since 2002 

Senior Vice President, Putnam Investments 

Judith Cohen (Born 1945) 

Vice President, Clerk and Assistant Treasurer 

Since 1993 

Wanda M. McManus (Born 1947) 

Vice President, Senior Associate Treasurer 

and Assistant Clerk 

Since 2005 

Nancy T. Florek (Born 1957) 

Vice President, Assistant Clerk, 

Assistant Treasurer and Proxy Manager 

Since 2005 

The address of each Officer is One Post Office Square, Boston, MA 02109.

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Putnam puts your
interests first

In January 2004, Putnam began introducing a number of voluntary initiatives designed to reduce fund expenses, provide investors with more useful information, and help safeguard the interests of all Putnam investors. Visit www.putnam.com for details.

Cost-cutting initiatives

Reduced sales charges The maximum sales charge for class A shares has been reduced to 5.25% for equity funds (formerly 5.75%) and 3.75% for most income funds (formerly 4.50%) . The maximum sales charge for class M shares has been reduced to 3.25% for equity funds (formerly 3.50%) .

* Lower class B purchase limit To help ensure that investors are in the most cost-effective share class, the maximum amount that can be invested in class B shares has been reduced to $100,000. (Larger trades or accumulated amounts will be refused.)

Ongoing expenses will be limited Through calendar 2006, total ongoing expenses, including management fees for all funds, will be maintained at or below the average of each fund’s industry peers in its Lipper load-fund universe. For more information, please see the Statement of Additional information.

Improved disclosure

Putnam fund prospectuses and shareholder reports have been revised to disclose additional information that will help shareholders compare funds and weigh their costs and risks along with their potential benefits. Shareholders will find easy-to-understand information about fund expense ratios, portfolio manager compensation, risk comparisons, turnover comparisons, brokerage commissions, and employee and trustee ownership of Putnam funds. Disclosure of breakpoint discounts has also been enhanced to alert investors to potential cost savings.

Protecting investors’ interests

Short-term trading fee introduced To discourage short-term trading, which can interfere with a fund’s long-term strategy, a 2% short-term trading fee may be imposed on any Putnam fund shares (other than money market funds) redeemed or exchanged within five calendar days of purchase.

* The maximum sales charge for class A shares of Putnam Limited Duration Government Income Fund (formerly Putnam 

  Intermediate U.S. Government Income Fund) and Putnam Floating Rate Income Fund remains 3.25%. 

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Fund information

Founded over 65 years ago, Putnam Investments was built around the concept that a balance between risk and reward is the hallmark of a well-rounded financial program. We manage over 100 mutual funds in growth, value, blend, fixed income, and international.

Investment Manager 

Putnam Investment 

Management, LLC 

One Post Office Square 

Boston, MA 02109 

Marketing Services 

Putnam Retail Management 

One Post Office Square 

Boston, MA 02109 

Custodian 

Putnam Fiduciary 

Trust Company 

Legal Counsel 

Ropes & Gray LLP 

Independent Registered 

Public Accounting Firm 

PricewaterhouseCoopers LLP 

Trustees 

John A. Hill, Chairman 

Jameson Adkins Baxter, 

Vice Chairman 

Charles B. Curtis 

Myra R. Drucker 

Charles E. Haldeman, Jr. 

Paul L. Joskow 

Elizabeth T. Kennan 

John H. Mullin, III 

Robert E. Patterson 

George Putnam, III 

W. Thomas Stephens 

Richard B. Worley 

Officers 

George Putnam, III 

President 

Charles E. Porter 

Executive Vice President, 

Associate Treasurer and 

Principal Executive Officer 

Jonathan S. Horwitz 

Senior Vice President 

and Treasurer 

Steven D. Krichmar 

Vice President and 

Principal Financial Officer 

Michael T. Healy 

Assistant Treasurer and 

Principal Accounting Officer 

Beth S. Mazor 

Vice President 

Daniel T. Gallagher 

Senior Vice President, 

Staff Counsel and 

Compliance Liaison 

James P. Pappas 

Vice President 

Richard S. Robie, III 

Vice President 

Mark C. Trenchard 

Vice President and 

BSA Compliance Officer 

Francis J. McNamara, III 

Vice President and 

Chief Legal Officer 

Charles A. Ruys de Perez 

Vice President and 

Chief Compliance Officer 

Judith Cohen 

Vice President, Clerk and 

Assistant Treasurer 

Wanda M. McManus 

Vice President, Senior Associate 

Treasurer and Assistant Clerk 

Nancy T. Florek 

Vice President, Assistant Clerk, 

Assistant Treasurer 

and Proxy Manager 

This report is for the information of shareholders of The Putnam Fund for Growth and Income. It may also be used as sales literature when preceded or accompanied by the current prospectus, the most recent copy of Putnam’s Quarterly Performance Summary, and Putnam’s Quarterly Ranking Summary. For more recent performance, please visit www.putnam.com. Investors should carefully consider the investment objective, risks, charges, and expenses of a fund, which are described in its prospectus. For this and other information or to request a prospectus, call 1-800-225-1581 toll free. Please read the prospectus carefully before investing. The fund’s Statement of Additional Information contains additional information about the fund’s Trustees and is available without charge upon request by calling 1-800-225-1581.

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Item 2. Code of Ethics:

(a) All officers of the Fund, including its principal executive, financial and accounting officers, are employees of Putnam Investment Management, LLC, the Fund's investment manager. As such they are subject to a comprehensive Code of Ethics adopted and administered by Putnam Investments which is designed to protect the interests of the firm and its clients. The Fund has adopted a Code of Ethics which incorporates the Code of Ethics of Putnam Investments with respect to all of its officers and Trustees who are employees of Putnam Investment Management, LLC. For this reason, the Fund has not adopted a separate code of ethics governing its principal executive, financial and accounting officers.

(c) In July 2004, Putnam Investment Management, LLC, the Fund's investment manager, Putnam Retail Management Limited Partnership, the Fund's principal underwriter, and Putnam Investments Limited, the sub-manager for a portion of the assets of certain funds as determined by Putnam Management from time to time, adopted several amendments to their Code of Ethics. Some of these amendments were adopted as a result of Putnam Investment Management's partial settlement order with the SEC on November 13, 2003. Insofar as such Code of Ethics applies to the Fund's principal executive officer, principal financial officer and principal accounting officer, the amendments provided for the following: (i) a 90-day blackout period for all shares of Putnam open-end funds (except for money market funds) purchased or sold (including exchanges into or out of a fund) by Putnam employees and certain family members; (ii) a one-year holding period for all access persons that operates in the same manner as the 90-day rule; (iii) delivery by Putnam employees to the Code of Ethics Administrator of both quarterly account statements for all brokerage accounts (irrespective of activity in the accounts) and account statements for any Putnam funds not held at Putnam or for any funds sub-advised by Putnam; (iv) a prohibition of Putnam employees from making more than 25 trades in individual securities in their personal accounts in any given quarter; (v) the extension of the existing prohibition of access persons from a purchase and sale or sale and purchase of an individual security within 60 days to include trading based on tax-lot election; (vi) the inclusion of trades in Marsh & McLennan Companies, Inc. (ultimate parent company of Putnam Investment Management) securities in pre-clearance and reporting requirements; (vii) a prohibition of limit and good-until-canceled orders as inconsistent with the requirements of daily pre-clearance; (viii) new limits and procedures for accounts managed by outside managers and brokers, in order for trading in such accounts to be exempt from pre-clearance requirements; (ix) a new gift and entertainment policy that imposes a reporting obligation on all meals and entertainment and new limits on non-meal entertainment; (x) a number of alternatives for the reporting of irregular activity.

In December 2004, additional amendments to the Code of Ethics were adopted. Insofar as such Code of Ethics applies to the Fund's principal executive officer, principal financial officer and principal accounting officer, the amendments provided for the following: (i) implementation of minimum monetary sanctions for violations of the Code; (ii) expansion of the definition of "access person" under the Code include all Putnam employees with access to non-public information regarding Putnam-managed mutual fund portfolio holdings; (iii) lengthening the period during which access persons are required to complete quarterly reports; (iv) reducing the maximum number of trades than can be made by Putnam employees in their personal accounts in

any calendar quarter from 25 trades to 10 trades; and (v) lengthening the required holding period for securities by access persons from 60 days to 90 days.

In March 2005, additional amendments to the Code of Ethics were adopted, that went into effect on April 1, 2005. Insofar as such Code of Ethics applies to the Fund’s principal executive officer, principal financial officer and principal accounting officer, the amendments (i) prohibit Putnam employees and their immediate family members from having any direct or indirect personal financial interest in companies that do business with Putnam (excluding investment holdings in public companies that are not material to the employee), unless such interest is disclosed and approved by the Code of Ethics Officer; (ii) prohibit Putnam employees from using Putnam assets, letterhead or other resources in making political or campaign contributions, solicitations or endorsements;(iii) require Putnam employees to obtain pre-clearance of personal political or campaign contributions or other gifts to government officials or political candidates in certain jurisdictions and to officials or candidates with whom Putnam has or is seeking to establish a business relationship and (iv) require Putnam employees to obtain pre-approval from Putnam’s Director of Government Relations prior to engaging in lobbying activities.

In July 2005, additional amendments to the Code of Ethics were adopted. Insofar as such Code of Ethics applies to the Fund's principal executive officer, principal financial officer and principal accounting officer, the amendments provided for an exception to the standard 90-day holding period (one year, in the case of employees deemed to be “access persons” under the Code) for shares of Putnam mutual funds in the case of redemptions from an employee’s account in a college savings plan qualified under Section 529 of the Internal Revenue Code. Under this exception, an employee may, without penalty under the Code, make “qualified redemptions” of shares from such an account less than 90 days (or one year, as applicable) after purchase. “Qualified redemptions” include redemptions for higher education purposes for the account beneficiary and redemptions made upon death or disability. The July 2005 amendments also provide that an employee may, for purposes of the rule limiting the number of trades per calendar quarter in an employee’s personal account to a maximum of 10, count all trades of the same security in the same direction (all buys or all sells) over a period of five consecutive business days as a single trade.

Item 3. Audit Committee Financial Expert:

The Funds' Audit and Pricing Committee is comprised solely of Trustees who are "independent" (as such term has been defined by the Securities and Exchange Commission ("SEC") in regulations implementing Section 407 of the Sarbanes-Oxley Act (the "Regulations")). The Trustees believe that each of the members of the Audit and Pricing Committee also possess a combination of knowledge and experience with respect to financial accounting matters, as well as other attributes, that qualify them for service on the Committee. In addition, the Trustees have determined that all members of the Funds' Audit and Pricing Committee meet the financial literacy requirements of the New York Stock Exchange's rules and that Mr. Patterson, Mr. Stephens and Mr. Worley qualify as "audit committee financial experts" (as such term has been defined by the Regulations) based on their review of their pertinent experience and education. Certain other Trustees, although not on the Audit and Pricing

Committee, would also qualify as "audit committee financial experts." The SEC has stated that the designation or identification of a person as an audit committee financial expert pursuant to this Item 3 of Form N-CSR does not impose on such person any duties, obligations or liability that are greater than the duties, obligations and liability imposed on such person as a member of the Audit and Pricing Committee and the Board of Trustees in the absence of such designation or identification.

Item 4. Principal Accountant Fees and Services:

The following table presents fees billed in each of the last two fiscal years for services rendered to the fund by the fund’s independent auditors:

Fiscal year	Audit	Audit-Related	Tax	All Other
ended	Fees	Fees	Fees	Fees
October 31,
2005	$ 225,071*	$--	$6,599	$ 9,843
October 31,
2004	$ 187,741*	$--	$6,226	$ 3,685

*: Includes fees of $10,433 and $16,537 billed by the fund’s independent auditor to the fund for audit procedures necessitated by regulatory and litigation matters for the fiscal years ended October 31, 2005 and October 31, 2004, respectively. These fees were reimbursed to the fund by Putnam.

For the fiscal years ended October 31, 2005 and October 31, 2004, the fund’s independent auditors billed aggregate non-audit fees in the amounts of $180,121 and $124,825 respectively, to the fund, Putnam Management and any entity controlling, controlled by or under common control with Putnam Management that provides ongoing services to the fund.

Audit Fees represents fees billed for the fund’s last two fiscal years.

Audit-Related Fees represents fees billed in the fund’s last two fiscal years for services traditionally performed by the fund’s auditor, including accounting consultation for proposed transactions or concerning financial accounting and reporting standards and other audit or attest services not required by statute or regulation.

Tax Fees represent fees billed in the fund’s last two fiscal years for tax compliance, tax planning and tax advice services. Tax planning and tax advice services include assistance with tax audits, employee benefit plans and requests for rulings or technical advice from taxing authorities.

All Other Fees Fees represent fees billed for services relating to an analysis of recordkeeping fees.

Pre-Approval Policies of the Audit and Pricing Committee. The Audit and Pricing Committee of the Putnam funds has determined that, as a matter of policy, all work performed for the funds by the funds’ independent auditors will be pre-approved by the Committee and will generally not be subject to pre-approval procedures.

Under certain circumstances, the Audit and Pricing Committee believes that it may be appropriate for Putnam Investment Management, LLC (“Putnam Management”) and certain of its affiliates to engage the services of the funds’ independent auditors, but only after prior approval by the Committee. Such requests are required to be submitted in writing to the Committee and explain, among other things, the nature of the proposed engagement, the estimated fees, and why this

work must be performed by that particular audit firm. The Committee will review the proposed engagement at its next meeting.

Since May 6, 2003, all work performed by the independent auditors for the funds, Putnam Management and any entity controlling, controlled by or under common control with Putnam Management that provides ongoing services to the fund was pre-approved by the Committee or a member of the Committee pursuant to the pre-approval policies discussed above. Prior to that date, the Committee had a general policy to pre-approve the independent auditor’s engagements for non-audit services with the funds, Putnam Management and any entity controlling, controlled by or under common control with Putnam Management that provides ongoing services to the fund.

The following table presents fees billed by the fund’s principal auditor for services required to be approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X.

Fiscal year	Audit-Related	Tax	All Other	Total Non-Audit
ended	Fees	Fees	Fees	Fees
October 31,
2005	$--	$ 62,968	$--	$--
October 31,
2004	$--	$--	$--	$--

Item 5. Audit Committee:

Not applicable

Item 6. Schedule of Investments:

Not applicable

Item 7. Disclosure of Proxy Voting Policies and Procedures For Closed-EndManagement Investment Companies:

Not applicable

Item 8. Purchases of Equity Securities by Closed-End Management InvestmentCompanies and Affiliated Purchasers:

Not applicable

Item 9. Submission of Matters to a Vote of Security Holders:

Not applicable

Item 10. Controls and Procedures:

(a) The registrant's principal executive officer and principal financial officer have concluded, based on their evaluation of the effectiveness of the design and operation of the registrant's disclosure controls and procedures as of a date within 90 days of the filing date of this report, that the design and operation of such procedures are generally effective to provide reasonable assurance that information required to be disclosed by the registrant in this report is recorded, processed, summarized and reported within the time periods specified in the Commission's rules and forms.

(b) Changes in internal control over financial reporting: Not applicable

Item 11. Exhibits:

(a) Not applicable

(b) A separate certification for each principal executive officer and principal financial officer of the registrant as required by Rule 30a-2 under the Investment Company Act of 1940, as amended, and the officer certifications as required by Section 906 of the Sarbanes-Oxley Act of 2002 are filed herewith.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

NAME OF REGISTRANT

By (Signature and Title):

/s/ Michael T. Healy
Michael T. Healy
Principal Accounting Officer

Date: December 29, 2005

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title):

/s/ Charles E. Porter
Charles E. Porter
Principal Executive Officer

Date: December 29, 2005

By (Signature and Title):

/s/Steven D. Krichmar
Steven D. Krichmar
Principal Financial Officer

Date: December 29, 2005

EX-99.CERT

Certifications

I, Charles E. Porter, a Principal Executive Officer of the funds listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on Attachment A:

2. Based on my knowledge, each report does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by each report;

3. Based on my knowledge, the financial statements, and other financial information included in each report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in each report;

4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a) designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which each report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c) evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of each report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant's other certifying officer and I have disclosed to each registrant's auditors and the audit committee of each registrant's board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect each registrant's ability to record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other employees who have a significant role in each registrant's internal control over financial reporting.

Date: December 28, 2005

/s/ Charles E. Porter
_______________________
Charles E. Porter
Principal Executive Officer

Certifications

I, Steven D. Krichmar, the Principal Financial Officer of the funds listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on Attachment A:

2. Based on my knowledge, each report does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by each report;

3. Based on my knowledge, the financial statements, and other financial information included in each report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in each report;

4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a) designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which each report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c) evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of each report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant's other certifying officer and I have disclosed to each registrant's auditors and the audit committee of each registrant's board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect each registrant's ability to record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other employees who have a significant role in each registrant's internal control over financial reporting.

Date: December 28, 2005

/s/ Steven D. Krichmar
_______________________
Steven D. Krichmar
Principal Financial Officer

Attachment A
N-CSR
Period (s) ended October 31, 2005
041	Putnam Global Income Fund
005	Putnam Global Equity Fund
008	Putnam Convertible Income-Growth Trust
004	Putnam Income Fund
002	The Putnam Fund for Growth and Income
840	Putnam Utilities Growth & Income Fund
2II	Putnam Capital Opportunities Fund
2OV	Putnam Mid-Cap Value Fund
582	Putnam Municipal Opportunities Trust
183	Putnam Municipal Bond Fund
052	Putnam Managed Municipal Income Trust
185	Putnam New York Investment Grade Municipal Trust
184	Putnam California Investment Grade Municipal Trust
2MI	Putnam Tax Smart Equity Fund

EX-99.906 CERT

Section 906 Certifications

I, Charles E. Porter, a Principal Executive Officer of the Funds listed on Attachment A, certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period ended October 31, 2005 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on Attachment A for the period ended October 31, 2005 fairly presents, in all material respects, the financial condition and results of operations of the Funds listed on Attachment A.

Date: December 28, 2005

/s/ Charles E. Porter
______________________
Charles E. Porter
Principal Executive Officer

Section 906 Certifications

I, Steven D. Krichmar, a Principal Financial Officer of the Funds listed on Attachment A,

certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period ended October 31, 2005 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on Attachment A for the period ended October 31, 2005 fairly presents, in all material respects, the financial condition and results of operations of the Funds listed on Attachment A.

Date: December 28, 2005

/s/ Steven D. Krichmar
______________________
Steven D. Krichmar
Principal Financial Officer

Attachment A
N-CSR
Period (s) ended October 31, 2005
041	Putnam Global Income Fund
005	Putnam Global Equity Fund
008	Putnam Convertible Income-Growth Trust
004	Putnam Income Fund
002	The Putnam Fund for Growth and Income
840	Putnam Utilities Growth & Income Fund
2II	Putnam Capital Opportunities Fund
2OV	Putnam Mid-Cap Value Fund
582	Putnam Municipal Opportunities Trust
183	Putnam Municipal Bond Fund
052	Putnam Managed Municipal Income Trust
185	Putnam New York Investment Grade Municipal Trust
184	Putnam California Investment Grade Municipal Trust
2MI	Putnam Tax Smart Equity Fund

EX-99.P CODE ETH

working@Putnam                                                August 2004

                            CODE OF ETHICS
CODE OF ETHICS

PUTNAM INVESTMENTS

[SCALE LOGO OMITTED]


It is the personal responsibility of every Putnam employee to avoid any
conduct that could create a conflict, or even the appearance of a
conflict, with our fund shareholders and other clients, or to do
anything that could damage or erode the trust our fund shareholders and
other clients place in Putnam and its employees.


TABLE OF CONTENTS

OVERVIEW.............................................................iii
PREAMBLE..............................................................vi
DEFINITIONS: Code of Ethics .........................................vii
SECTION I. Personal Securities Rules for All Employees ............... 1
A. Pre-clearance and the Restricted List ............................. 1
B. Prohibited Transactions.............................................5
C. Discouraged Transactions.......................................... 11
D. Exempted Transactions .............................................11
SECTION II. Additional Special Rules for Personal Securities
Transactions of Access Persons and Certain Investment Professionals.. 13
SECTION III. General Rules for All Employees .........................18
SECTION IV. Special Rules for Officers and Employees of Putnam
Investments Limited ................................................. 29
SECTION V. Reporting Requirements for All Employees.................. 31
SECTION VI. Education Requirements ...................................34
SECTION VII. Compliance and Appeal Procedures.........................35
APPENDIX A: Policy Statement Concerning Insider Trading Prohibitions
PREAMBLE ............................................................ 37
DEFINITIONS: Insider Trading..........................................38
SECTION I. Rules Concerning Inside Information .......................39
SECTION II. Overview of Insider Trading ..............................41
APPENDIX B: Policy Statement Regarding Employee Trades in Shares of
Putnam Closed-End Funds ..............................................45
APPENDIX C: Contra-Trading Rule Clearance Form........................46
APPENDIX D: AIMR Code of Ethics and Standards of
Professional Conduct .................................................47
APPENDIX E: Report of Entertainment Form..............................53
INDEX ................................................................55


OVERVIEW

Every Putnam employee is required, as a condition of continued
employment, to read, understand, and comply with the entire Code of
Ethics. Additionally, employees are expected to comply with the policies
and procedures contained within the Putnam Employee Handbook, which can
be accessed online through www.ibenefitcenter.com. This overview is
provided only as a convenience and is not intended to substitute for a
careful reading of the complete document.

It is the personal responsibility of every Putnam employee to avoid any
conduct that could create a conflict, or even the appearance of a
conflict, with our fund shareholders or other clients, or do anything
that could damage or erode the trust our clients place in Putnam and its
employees. This is the spirit of the Code of Ethics. In accepting
employment at Putnam, every employee accepts the absolute obligation to
comply with the letter and the spirit of the Code of Ethics. Failure to
comply with the spirit of the Code of Ethics is just as much a violation
of the Code as failure to comply with the written rules of the Code.

The rules of the Code cover activities, including personal securities
transactions, of Putnam employees, certain family members of employees,
and entities (such as corporations, trusts, or partnerships) that
employees may be deemed to control or influence.

Sanctions will be imposed for violations of the Code of Ethics.
Sanctions may include bans on personal trading, reductions in salary
increases or bonuses, disgorgement of trading profits, suspension of
employment, and termination of employment.

Insider trading

Putnam employees are forbidden to buy or sell any security while either
Putnam or the employee is in possession of material, non-public
information (inside information) concerning the security or the issuer.
A violation of Putnam's insider trading policies may result in criminal
and civil penalties, including imprisonment and substantial fines. An
employee aware of or in possession of inside information must report it
immediately to the Code of Ethics Officer. See Appendix A, Section ll:
Overview of Insider Trading.

Conflicts of interest

The Code of Ethics imposes limits on activities of Putnam employees
where the activity may conflict with the interests of Putnam or its
clients. These include limits on the receipt and solicitation of gifts
and on service as a fiduciary for a person or entity outside of Putnam.

For example, Putnam employees generally may not accept gifts over $100
in total value in a calendar year from any entity or any supplier of
goods or services to Putnam. In addition, a Putnam employee may not
serve as a director of any corporation or other entity without prior
approval of the Code of Ethics Officer, and Putnam employees may not be
members of investment clubs.

Confidentiality

Information about Putnam clients and Putnam investment activity and
research is proprietary and confidential and may not be disclosed or
used by any Putnam employee outside Putnam without a valid business
purpose.

Personal securities trading

Putnam employees may not buy or sell any security for their own account
without clearing the proposed transaction in advance. Clearance is
facilitated through the online pre-clearance system for equity
securities, and directly with the Code of Ethics Administrator for
fixed-income securities and transactions in Putnam closed-end funds.
Certain securities are exempted from this pre-clearance requirement
(e.g., shares of open-end (not closed-end) mutual funds).

Clearance must be obtained in advance, between 11:30 a.m. and 4:00 p.m.
Eastern Standard Time (EST) on the day of the trade, except in the case
of a trade for up to 1,000 shares of stock of an issuer whose
capitalization exceeds $5 billion, clearance may be obtained between
9:00 a.m. and 4:00 p.m. EST on the day of the trade.  A clearance is
valid only for the day it is obtained. Putnam employees are strongly
discouraged from engaging in excessive trading for their personal
accounts. Beginning with the fourth quarter of 2004, employees will be
prohibited from making more than 25 trades in individual securities.
Trading in excess of this level will be reviewed with the Code of Ethics
Oversight Committee.

Putnam mutual funds

All employees and certain family members are subject to a minimum 90-day
holding period for shares in Putnam's open-end mutual funds. This
restriction does not apply to Putnam's money market funds. Except in
limited circumstances, all employees must hold Putnam open-end fund
shares in accounts at Putnam Preferred Access.

Portfolio managers and others with access to investment information
(so-called "Access Persons") are subject to a minimum one-year holding
period for holding Putnam open-end fund shares.

Short selling

Putnam employees are prohibited from short selling any security, whether
or not it is held in a Putnam client portfolio, except that short
selling against broad market indexes and "against the box" are
permitted. Note, however, that short selling "against the box" or
otherwise hedging an investment in shares of Marsh & McLennan (MMC)
stock is prohibited.

Confirmations of trading and periodic account statements

All Putnam employees must have their brokers send confirmations and
statements of personal securities transactions, including transactions
of immediate family members and accounts over which the employee has
investment discretion, to the Code of Ethics Officer. Employees must
contact the Code of Ethics Administrator to obtain an authorization
letter from Putnam for setting up a personal brokerage account.

Quarterly and annual reporting

Access persons must report all their securities transactions in each
calendar quarter to the Code of Ethics Officer within 10 days after the
end of the quarter. All Access Persons must disclose all personal
securities holdings (even those to which pre-clearance may not apply)
upon commencement of employment and thereafter on an annual basis. You
will be notified if these requirements apply to you. If these
requirements apply to you and you fail to report as required, salary
increases and bonuses may be reduced. Egregious conduct, e.g., willful
failures to report, will be subject to harsher sanctions, which may
include termination of employment.

IPOs and private placements

Putnam employees may not buy any securities in an initial public
offering or in a private placement, except in limited circumstances when
prior written authorization is obtained.

Personal securities transactions by Access Persons
and certain investment professionals

The Code imposes several special restrictions on personal securities
transactions by Access Persons and certain investment professionals,
which are summarized as follows. (Refer to Section II for details):

* 60-Day Holding Period. No Access Person shall purchase and then sell
at a profit, or sell and then repurchase at a lower price, any security
or related derivative security within 60 calendar days.

* 7-Day Rule. Before a portfolio manager places an order to buy a
security for any portfolio he manages, he must sell from his personal
account any such security or related derivative security purchased
within the preceding seven calendar days and disgorge any profit from
the sale.

* Blackout Rules. No portfolio manager may sell any security or related
derivative security for her personal account until seven calendar days
have passed since the most recent purchase of that security or related
derivative security by any portfolio she manages. No portfolio manager
may buy any security or related derivative security for his personal
account until seven calendar days have passed since the most recent sale
of that security or related derivative security by any portfolio he
manages.

* Contra-Trading Rule. No portfolio manager may sell out of her personal
account any security or related derivative security that is held in any
portfolio she manages unless she has received the written approval of an
appropriate CIO and the Code of Ethics Officer.

* No portfolio manager may cause a Putnam client to take action for the
manager's own personal benefit.

Similar rules limit personal securities transactions by analysts,
co-managers, and chief investment officers. Please read these rules
carefully as you are responsible for understanding the restrictions.


PREAMBLE

It is the personal responsibility of every Putnam employee to avoid any
conduct that would create a conflict, or even the appearance of a
conflict, with our fund shareholders or other clients, or do anything
that could damage or erode the trust our clients place in Putnam and its
employees. This is the spirit of the Code of Ethics. In accepting
employment at Putnam, every employee also accepts the absolute
obligation to comply with the letter and the spirit of the Code of
Ethics. Failure to comply with the spirit of the Code of Ethics is just
as much a violation of the Code as failure to comply with the written
rules of the Code. Sanctions will be imposed for violations of the Code
of Ethics, including the Code's reporting requirements.

Sanctions may include bans on personal trading, reductions in salary
increases or bonuses, disgorgement of trading profits, suspension of
employment, and termination of employment.

Putnam Investments is required by law to adopt a Code of Ethics. The
purposes of the law are to ensure that companies and their employees
comply with all applicable laws and to prevent abuses in the investment
advisory business that can arise when conflicts of interest exist
between the employees of an investment advisor and its clients. By
adopting and enforcing a Code of Ethics, we strengthen the trust and
confidence reposed in us by demonstrating that, at Putnam, client
interests come before personal interests.

The Code that follows represents a balancing of important interests. On
the one hand, as a registered investment advisor, Putnam owes a duty of
undivided loyalty to its clients, and must avoid even the appearance of
a conflict that might be perceived as abusing the trust they have placed
in Putnam. On the other hand, Putnam does not want to prevent
conscientious professionals from investing for their own account where
conflicts do not exist or are so attenuated as to be immaterial to
investment decisions affecting Putnam clients.

When conflicting interests cannot be reconciled, the Code makes clear
that, first and foremost, Putnam employees owe a fiduciary duty to
Putnam clients. In most cases, this means that the affected employee
will be required to forego conflicting personal securities transactions.
In some cases, personal investments will be permitted, but only in a
manner, which, because of the circumstances and applicable controls,
cannot reasonably be perceived as adversely affecting Putnam client
portfolios or taking unfair advantage of the relationship Putnam
employees have to Putnam clients.

The Code contains specific rules prohibiting defined types of conflicts.
Because every potential conflict cannot be anticipated in advance, the
Code also contains certain general provisions prohibiting conflict
situations. In view of these general provisions, it is critical that any
individual who is in doubt about the applicability of the Code in a
given situation seek a determination from the Code of Ethics Officer
about the propriety of the conduct in advance. The procedures for
obtaining such a determination are described in Section VII of the Code.

It is critical that the Code be strictly observed. Not only will
adherence to the Code ensure that Putnam renders the best possible
service to its clients, it will ensure that no individual is liable for
violations of law.

It should be emphasized that adherence to this policy is a fundamental
condition of employment at Putnam. Every employee is expected to adhere
to the requirements of this Code of Ethics despite any inconvenience
that may be involved. Any employee failing to do so may be subject to
such disciplinary action, including financial penalties and termination
of employment, as determined by the Code of Ethics Oversight Committee
or the Chief Executive Officer of Putnam Investments.


DEFINITIONS: Code of Ethics

The words below are defined specifically for the purpose of Putnam's
Code of Ethics.

Gender references in the Code of Ethics alternate.

Rule of construction regarding time periods

Unless the context indicates otherwise, time periods used in the Code of
Ethics shall be measured inclusively, i.e., beginning on the dates from
which the measurement is made.

Access Persons

Access Persons are (a) employees within Putnam's Investment Division,
and (b) all other employees of Putnam who, in connection with their
regular duties, have access to information regarding purchases or sales
of portfolio securities by a Putnam mutual fund, or who have access to
information regarding recommendations with respect to such purchases or
sales (such as certain Information Services Division employees and
certain members of the Legal and Compliance Department). Each employee
will be informed if he or she is considered a Code of Ethics Access
Person. The Code of Ethics Officer maintains a list of all Access
Persons.

Code of Ethics Administrator

The individual designated by the Code of Ethics Officer to assume
responsibility for day-to-day, nondiscretionary administration of this
Code. The current Code of Ethics Administrator is Laura Rose, who can be
reached at extension 11104.

Code of Ethics Officer

The Putnam officer who has been assigned the responsibility of enforcing
and interpreting this Code. The Code of Ethics Officer shall be the
Chief Compliance Officer or such other person as is designated by the
Chief Executive Officer of Putnam Investments. If the Code of Ethics
Officer is unavailable, the Deputy Code of Ethics Officer shall act in
his or her stead. The Code of Ethics Officer is Tony Ruys de Perez. The
Deputy Code of Ethics Officer is Kathleen Griffin.

Code of Ethics Oversight Committee

Has oversight responsibility for administering the Code of Ethics.
Members include the Code of Ethics Officer and other members of Putnam's
senior management approved by the Chief Executive Officer of Putnam.

Immediate family

Spouse, minor children, or other relatives living in the same household
as the Putnam employee.

Narrow-based derivative

A future, swap, option, or similar derivative instrument whose return is
determined by reference to fewer than 25 underlying issuers. Single
stock futures and exchange traded funds based on fewer than 25 issuers
are included.

Policy statements

The Policy Statement Concerning Insider Trading Prohibitions attached to
the Code as Appendix A and the Policy Statement Regarding Employee
Trades in Shares of Putnam closed-end funds attached to the Code as
Appendix B.

Private placement

Any offering of a security not offered to the public and not requiring
registration with the relevant securities authorities.

Purchase or sale of a security

Any acquisition or transfer of any interest in the security for direct
or indirect consideration; this includes the writing of an option.

Putnam

Any or all of Putnam Investments Trust, and its subsidiaries, any one of
which shall be a Putnam company.

Putnam client

Any of the Putnam mutual funds, or any advisory, trust, or other client
of Putnam.

Putnam employee (or employee)

Any employee of Putnam

Restricted list

The list established in accordance with Rule 1 of Section I.A.

Security

Any type or class of equity or debt security; any rights relating to a
security, such as warrants, convertible securities, and any narrow-based
derivative. Pre-clearance in all trades for any narrow-based derivative
is required.  Unless otherwise noted, the term security does not
include: currencies, direct and indirect obligations of the U.S.
government and its agencies, commercial paper, certificates of deposit,
repurchase agreements, bankers' acceptances, any other money market
instruments. Exchange traded index funds containing a portfolio or
securities of 25 or more issuers (e.g., SPDRs, WEBs, QQQs), commodities,
and any option on a broad-based market index or an exchange-traded
futures contract or option thereon are excluded.

Transaction for a personal account (or personal securities transaction)

Securities transactions: (a) for the personal account of any employee;
(b) for the account of a member of the family of any employee; (c) for
the account of a partnership in which a Putnam employee or immediate
family member is a general partner or a partner with investment
discretion; (d) for the account of a trust in which a Putnam employee or
immediate family member is a trustee with investment discretion; (e) for
the account of a closely-held corporation in which a Putnam employee or
immediate family member holds shares and for which he has investment
discretion; and (f ) for any account other than a Putnam client account,
which receives investment advice of any sort from the employee or
immediate family member, or as to which the employee or immediate family
member has investment discretion.


SECTION I

Personal Securities Rules for All Employees

A. Pre-clearance and the Restricted List

Rule 1

No Putnam employee shall purchase or sell for his personal account any
security (other than shares of open-end investment companies) without
prior clearance obtained through Putnam's intranet pre-clearance system
(under the @Putnam tab of www.ibenefitcenter.com). Fixed-income
securities must be pre-cleared by calling the Code of Ethics
Administrator, and there are special rules for trading in Putnam
closed-end funds. See Appendix B. Subject to the limited exceptions
below, no clearance will be granted for securities appearing on the

Restricted List. Securities will be placed on the Restricted List in the
following circumstances:

(a) When orders to purchase or sell such security have been entered for
any Putnam client, or the security is being actively considered for
purchase for any Putnam client, unless the security is a nonconvertible
investment grade rated (BBB by S&P or Baa by Moody's) fixed-income
investment;

(b) When such a security is a voting security of a corporation in the
banking, savings and loan, communications, or gaming (i.e., casinos)
industries, if holdings of Putnam clients in that corporation exceed 7%
(for public utilities, the threshold is 4%);

(c) When, in the judgment of the Code of Ethics Officer, other
circumstances warrant restricting personal transactions of Putnam
employees in a particular security;

(d) The circumstances described in the Policy Statement Concerning
Insider Trading Prohibitions, attached as Appendix A.

Reminder: Securities for an employee's personal account include
securities owned by certain family members of a Putnam employee. Thus,
this Rule prohibits certain trades by family members of Putnam
employees. See Definitions.

Compliance with this rule does not exempt an employee from complying
with any other applicable rules of the Code, such as those described in
Section III. In particular, Access Persons and certain investment
professionals must comply with the special rules set forth in Section
II.


IMPLEMENTATION

A. Maintenance of Restricted List. The Restricted List shall be
maintained by the Code of Ethics Administrator.

B. Consulting Restricted List. An employee wishing to trade any security
for his personal account shall first obtain clearance through Putnam's
Intranet pre-clearance system. The system may be accessed online at
ibenefitcenter.com. Select Employee Essentials under the @Putnam tab.
Employees may pre-clear all securities between 11:30 a.m. and 4:00 p.m.
EST, and may pre-clear purchases or sales of up to 1,000 shares of
issuers having a market capitalization of more than $5 billion between
9:00 a.m. and 4:00 p.m. EST.

Requests to make personal securities transactions may not be made using
the system or presented to the Code of Ethics Administrator after
4:00 p.m. EST.

Pre-clearance of fixed income securities and Putnam closed-end funds
must be made by calling the Code of Ethics Administrator.

The pre-clearance system will inform the employee whether the security
may be traded and whether trading in the security is subject to the
"Large Cap" limitation. The response of the pre-clearance system as to
whether a security appears on the Restricted List and, if so, whether it
is eligible for the exceptions set forth after this Rule shall be final,
unless the employee appeals to the Code of Ethics Officer, using the
procedure described in Section VII, regarding the request to trade a
particular security.

A clearance is only valid for trading on the day it is obtained. Trades
in securities listed on Asian or European stock exchanges, however, may
be executed within one business day after pre-clearance is obtained.

If a security is not on the Restricted List, other classes of securities
of the same issuer (e.g., preferred or convertible preferred stock) may
be on the Restricted List. It is the employee's responsibility to
identify with particularity the class of securities for which permission
is being sought for a personal investment.

If the pre-clearance system does not recognize a security, or if an
employee is unable to use the system or has any questions with respect
to the system or pre-clearance, the employee may consult the Code of
Ethics Administrator. The Code of Ethics Administrator shall not have
authority to answer any questions about a security other than whether
trading is permitted. The response of the Code of Ethics Administrator
as to whether a security appears on the Restricted List and, if so,
whether it is eligible for any applicable exceptions set forth after
this Rule shall be final, unless the employee appeals to the Code of
Ethics Officer, using the procedure described in Section VII, regarding
the request to trade a particular security.


EXCEPTIONS

A. Large Cap Exception. If a security appearing on the Restricted List
is an equity security for which the issuer has a market capitalization
(defined as outstanding shares multiplied by current price per share) of
over $5 billion, then a Putnam employee may purchase or sell up to 1,000
shares of the security per day for his personal account. This exception
does not apply if the security appears on the Restricted List in the
circumstances described in subpart (b), (c), or (d) of Rule 1.

B. Pre-clearing Transactions Effected by Share Subscription. The
purchase of securities made by subscription rather than on an exchange
are limited to issuers having a market capitalization of $5 billion or
more and are subject to a 1,000 share limit. The following are
procedures to comply with Rule 1 when effecting a purchase or sale of
shares by subscription:

(a) The Putnam employee must pre-clear the trade on the day he or she
submits a subscription to the issuer, rather than on the actual day of
the trade since the actual day of the trade typically will not be known
to the employee who submits the subscription. At the time of
pre-clearance, the employee will be told whether the purchase is
permitted (in the case of a corporation having a market capitalization
of $5 billion or more), or not permitted (in the case of a smaller
capitalization issuer).

(b) The subscription for any purchase or sale of shares must be reported
on the employee's quarterly personal securities transaction report,
noting the trade was accomplished by subscription.

(c) Because no brokers are involved in the transaction, the confirmation
requirement will be waived for these transactions, although the Putnam
employee must provide the Legal and Compliance Department with any
transaction summaries or statements sent by the issuer.

C. Trades in Approved Discretionary Brokerage Accounts. A transaction
does not need to be pre-cleared if it takes place in an account that the
Code of Ethics Officer has approved in writing as exempt from the
pre-clearance requirement. In the sole discretion of the Code of Ethics
Officer accounts that will be considered for exclusion from the
pre-clearance requirement are only those for which an employee's
securities broker or investment advisor has complete discretion (a
discretionary account) and the following conditions are met (i) the
employee certifies annually in writing that the employee has no
influence over the transactions in the discretionary account and is not
aware of the transactions in the discretionary account prior to their
execution, (ii) the compliance department of the employee's broker or
investment advisor certifies annually in writing that the employee has
no influence over the transactions in the discretionary account and is
not aware of the transactions in the discretionary account prior to
their execution; and (iii) each calendar quarter, the broker or
investment advisor sends Putnam's Code of Ethics Administrator copies of
each quarterly statement for the discretionary account. Employees
wishing to seek such an exemption must send a written request to the
Code of Ethics Administrator.


COMMENTS

* Pre-clearance. Subpart (a) of Rule 1 is designed to avoid the conflict
of interest that might occur when an employee trades for his personal
account a security that currently is being traded or is likely to be
traded for a Putnam client. Such conflicts arise, for example, when the
trades of an employee might have an impact on the price or availability
of a particular security, or when the trades of the client might have an
impact on price to the benefit of the employee. Thus, exceptions involve
situations where the trade of a Putnam employee is unlikely to have an
impact on the market.

* Regulatory Limits. Owing to a variety of federal statutes and
regulations in the banking, savings and loan, communications, and gaming
industries, it is critical that accounts of Putnam clients not hold more
than 10% of the voting securities (5% for public utilities) of any
issuer in those industries. Because of the risk that the personal
holdings of Putnam employees may be aggregated with Putnam holdings for
these purposes, subpart (b) of this Rule limits personal trades in these
areas. The 7% limit (4% for public utilities) will allow the regulatory
limits to be observed.

* Options. For the purposes of this Code, options are treated like the
underlying security. See Definitions. Thus, an employee may not
purchase, sell, or "write" option contracts for a security that is on
the Restricted List. The automatic exercise of an options contract (the
purchase or writing of which was previously pre-cleared) does not have
to be pre-cleared. Note, however, that the sale of securities obtained
through the exercise of options must be pre-cleared.

* Involuntary transactions. Involuntary personal securities transactions
are exempted from the Code. Special attention should be paid to this
exemption. (See Section I.D.)

* Tender offers. This Rule does not prohibit an employee from tendering
securities from his personal account in response to an any and all
tender offer, even if Putnam clients are also tendering securities. A
Putnam employee is, however, prohibited from tendering securities from
his personal account in response to a partial tender offer, if Putnam
clients are also tendering securities.

* MMC securities. The pre-clearance, reporting and the rules applicable
to personal trading apply to securities of MMC, including MMC shares
held in the Putnam 401(k) plans and in the MMC Stock Purchase Plan.


SANCTION GUIDELINES

A. Failure to Pre-clear a Personal Trade

* First violation: One month trading ban with written warning that a
future violation will result in a longer trading ban.

* Second violation: Three month trading ban and written notice to the
Senior Managing Director of the employee's division.

* Third violation: Six month trading ban with possible longer or
permanent trading ban based upon review by Code of Ethics Oversight
Committee.

B. Failure to Pre-clear Securities on the Restricted List

* First violation: Disgorgement of any profit from the transaction, one
month trading ban, and written warning that a future violation will
result in a longer trading ban.

* Second violation: Disgorgement of any profit from the transaction,
three month trading ban, and written notice to the Senior Managing
Director of the employee's division.

* Third violation: Disgorgement of any profit from the transaction, and
six month trading ban with possible longer or permanent trading ban
based upon review by Code of Ethics Oversight Committee.

NOTE

These are the sanction guidelines for successive failures to pre-clear
personal trades within a two-year period. The Code of Ethics Oversight
Committee retains the right to increase or decrease the sanction for a
particular violation in light of the circumstances. The Committee's
belief that an employee has violated the Code of Ethics intentionally
will result in more severe sanctions than outlined in the guidelines
above. The sanctions described in paragraph B apply to Restricted List
securities that are: (a) small-cap stocks (i.e., stocks not entitled to
the Large Cap exception) and (b) large-cap stocks that exceed the daily
1,000 share maximum permitted under the Large Cap exception. Failure to
pre-clear an otherwise permitted trade of up to 1,000 shares of a
large-cap security is subject to the sanctions described above in
paragraph A.

B. Prohibited Transactions

Rule 1

Putnam employees are prohibited from short selling any security, whether
or not the security is held in a Putnam client portfolio. Employees are
prohibited from hedging investments made in securities of MMC.


EXCEPTIONS

Short selling against broad market indexes (such as the Dow Jones
Industrial Average, the NASDAQ index, and the S&P 100 and 500 indexes)
and short selling against the box are permitted (except that short
selling shares of MMC against the box is not permitted).

Rule 2

No Putnam employee shall purchase any security for her personal account
in an initial public offering.


EXCEPTION

Pre-existing Status Exception. A Putnam employee shall not be barred by
this Rule or by Rule 1(a) of Section I.A. from purchasing securities for
her personal account in connection with an initial public offering of
securities by a bank or insurance company when the employee's status as
a policyholder or depositor entitles her to purchase securities on terms
more favorable than those available to the general public, in connection
with the bank's conversion from mutual or cooperative form to stock
form, or the insurance company's conversion from mutual to stock form,
provided that the employee has had the status entitling her to purchase
on favorable terms for at least two years. This exception is only
available with respect to the value of bank deposits or insurance
policies that an employee owns before the announcement of the initial
public offering. This exception does not apply, however, if the security
appears on the Restricted List in the circumstances set forth in
subparts (b), (c), or (d) of Section I.A., Rule 1.


IMPLEMENTATION

A. General Implementation. An employee shall inquire, before any
purchase of a security for her personal account, whether the security to
be purchased is being offered pursuant to an initial public offering. If
the security is offered through an initial public offering, the employee
shall refrain from purchasing that security for her personal account
unless the exception applies.

B. Administration of Exception. If the employee believes the exception
applies, she shall consult the Code of Ethics Administrator concerning
whether the security appears on the Restricted List and if so, whether
it is eligible for this exception.


COMMENTS

* The purpose of this Rule is twofold. First, it is designed to prevent
a conflict of interest between Putnam employees and Putnam clients who
might be in competition for the same securities in a limited public
offering. Second, the Rule is designed to prevent Putnam employees from
being subject to undue influence as a result of receiving favors in the
form of special allocations of securities in a public offering from
broker-dealers who seek to do business with Putnam.

* Purchases of securities in the immediate after-market of an initial
public offering are not prohibited, provided they do not constitute
violations of other portions of the Code of Ethics. For example,
participation in the immediate after-market as a result of a special
allocation from an underwriting group would be prohibited by Section
III, Rule 3 concerning gifts and other favors.

* Public offerings subsequent to initial public offerings are not deemed
to create the same potential for competition between Putnam employees
and Putnam clients because of the pre-existence of a market for the
securities.

Rule 3

No Putnam employee shall purchase any security for his personal account
in a limited private offering or private placement. Privately placed
limited partnerships are specifically included in this Rule.


COMMENTS

* The purpose of this Rule is to prevent a Putnam employee from
investing in securities for his own account pursuant to a limited
private offering that could compete with or disadvantage Putnam clients,
and to prevent Putnam employees from being subject to efforts to curry
favor by those who seek to do business with Putnam.

* Exemptions to the prohibition will generally not be granted where the
proposed investment relates directly or indirectly to investments by a
Putnam client, or where individuals involved in the offering (including
the issuers, broker, underwriter, placement agent, promoter, fellow
investors and affiliates of the foregoing) have any prior or existing
business relationship with Putnam or a Putnam employee, or where the
Putnam employee believes that such individuals may expect to have a
future business relationship with Putnam or a Putnam employee.

* An exemption may be granted, subject to reviewing all the facts and
circumstances, for investments in:

(a) Pooled investment funds, including hedge funds, subject to the
condition that an employee investing in a pooled investment fund would
have no involvement in the activities or decision-making process of the
fund except for financial reports made in the ordinary course of the
fund's business, and subject to the condition that the hedge fund does
not invest significantly in registered investment companies.

(b) Private placements where the investment cannot relate, or be
expected to relate, directly or indirectly to Putnam or investments by a
Putnam client.

* Employees who apply for an exemption will be expected to disclose to
the Code of Ethics Officer in writing all facts and relationships
relating to the proposed investment.

* Applications to invest in private placements will be reviewed by the
Code of Ethics Oversight Committee. This review will take into account,
among other factors, the considerations described in the preceding
comments.

Rule 4

No Putnam employee shall purchase or sell any security for her personal
account or for any Putnam client account while in possession of
material, nonpublic information concerning the security or the issuer.


EXCEPTIONS

None. Please read Appendix A, Policy Statement Concerning Insider
Trading Prohibitions.

Rule 5

No Putnam employee shall purchase from or sell to a Putnam client any
securities or other property for his personal account, nor engage in any
personal transaction to which a Putnam client is known to be a party, or
which transaction may have a significant relationship to any action
taken by a Putnam client.


EXCEPTIONS

None.

IMPLEMENTATION

It shall be the responsibility of every Putnam employee to make inquiry
prior to any personal transaction sufficient to satisfy himself that the
requirements of this Rule have been met.


COMMENT

This rule is required by federal law. It does not prohibit a Putnam
employee from purchasing any shares of an open-end Putnam fund. The
policy with respect to employee trading in closed-end Putnam funds is
attached as Appendix B.

Rule 6

Putnam employees may not hold shares of Putnam open-end U.S. mutual
funds other than through accounts maintained at Putnam through Putnam
Preferred Access (PPA). Employees placing purchase orders in shares of
Putnam open-end funds must place such orders through Putnam and not
through an outside broker or other intermediary. Employees redeeming or
exchanging shares of Putnam open-end funds must place those orders
through Putnam and not through an outside broker or other intermediary.
Contact a PPA representative at 1-800-634-1590 for instructions on how
to transfer these funds.

NOTE:

For purposes of this Rule, "employee" includes:

* Members of the immediate family of a Putnam employee who share the
same household as the employee or for whom the Putnam employee has
investment discretion (family member);

* Any trust in which a Putnam employee or family member is a trustee
with investment discretion and in which such Putnam employee or any
family member are collectively beneficiaries;

* Any closely-held entity (such as a partnership, limited liability
company, or corporation) in which a Putnam employee and his or her
family members hold a controlling interest and with respect to which
they have investment discretion; and

* Any account (including any retirement, pension, deferred compensation,
or similar account) in which a Putnam employee or family member has a
substantial economic interest and over which said Putnam employee or
family member exercises investment discretion.


COMMENTS

* These requirements also apply to self-directed IRA accounts holding
Putnam fund shares.

* For Putnam Profit Sharing Plan or other Putnam deferred compensation
accounts, trades may continue to be placed through ibenefitcenter.com.

* These Rules apply to variable insurance accounts, which invest in
Putnam Variable Trust such as the Putnam/Hartford Capital Manager.
Employees must designate Putnam Retail Management as the broker of
record for all such accounts.


EXCEPTION

Retirement, pension, deferred compensation and similar accounts that
cannot be legally transferred to Putnam are not subject to the
requirement. For example, a spouse of a Putnam employee may have a
401(k) plan with her employer that invests in Putnam funds. Any employee
who continues to hold shares in open-end Putnam funds outside of Putnam
must notify the Code of Ethics Officer in writing of the account
information, provide the reason why the account cannot be transferred to
Putnam and arrange for a quarterly statement of transaction in such
account to be sent to the Code of Ethics Administrator.

Rule 7

(a) Employees defined in Rule 6 may not, within a 90-calendar day
period, make a purchase followed by a sale, or a sale followed by a
purchase, of shares of the same open-end Putnam mutual fund even if the
transactions occur in different accounts.

(b) Employees who are Access Persons may not, within a one-year period,
make a purchase followed by a sale, or a sale followed by a purchase, of
shares of the same open-end Putnam mutual fund or of shares of any U.S.
registered mutual fund to which Putnam acts as advisor or sub-advisor
even if the transactions occur in different accounts.


COMMENTS

* This restriction applies across all accounts maintained by an employee
as follows:

An employee who buys shares of an open-end Putnam mutual fund may not
sell any shares of the same mutual fund until 90 calendar days have
passed.

Example. If an employee buys shares of a Putnam fund on Day 1 for a
retail account and then sells (by exchange) shares of the same fund for
his or her Putnam Profit Sharing 401(k) Plan account on Day 85, the
employee has violated the rule.

Similarly, an employee who sells shares of an open-end Putnam mutual
fund may not buy any shares of the same mutual fund until 90 calendar
days have passed.

Example. If an employee sells shares of a Putnam fund on day 1 for a
retail account and then sells (by exchange out) shares of the same fund
for his or her Putnam Profit Sharing 401(k) Plan account on day 85, the
employee may not buy (or exchange in) shares of that fund in any account
until day 176, which is more than 90 days after the most recent sale of
shares of that fund.

* The purpose of these blackout periods restriction is to prevent any
market timing, or appearance of market timing activity.

* This Rule applies to transactions by a Putnam employee in any type of
account, including retail, IRA, variable annuity, college savings 529
plans, Profit Sharing 401(k) Plan, and any deferred compensation
accounts.

* The minimum sanction for an initial violation of the blackout period
shall be disgorgement of any profit made on the transaction. Additional
sanctions may apply, including termination of employment.


EXCEPTIONS

A. This restriction does not apply to Putnam's money market funds and
Putnam Stable Value Fund.

B. Profit Sharing 401(k) Plan Contributions and Payroll Deductions. The
90-day restriction is not triggered by initial allocation of regular
employee or employer contributions or forfeitures to an employee's
account under the terms of Putnam employee benefit plans or a Putnam
payroll deduction direct investment program; later exchanges of these
contributions will be subject to the 90-day blackout period.

C. Systematic Programs. This restriction does not apply with respect to
shares sold or acquired as a result of participation in a systematic
program for contributions, withdrawals or exchanges, provided that an
election to participate in any such program and the participation dates
of the program may not be changed more often than quarterly after the
program is elected by the employee. Access Persons may elect a quarterly
or semiannual rebalancing program although it may only be changed on an
annual basis;

D. Employee Benefit Plan Withdrawals and Distributions. This restriction
does not apply with respect to shares sold for withdrawals, loans or
distributions under the terms of Putnam employee benefit plans;

E. Dividends, Distributions, Mergers, and Share Class Conversions. This
restriction does not apply with respect to the requisitioned shares as a
result of reinvestment of dividends, distributions, mergers, conversions
of share classes, or other similar actions. Subsequent transactions with
respect to the shares will be covered.

F. In special situations, Putnam's Code of Ethics Oversight Committee
may grant exceptions to the blackout periods as a result of death,
disability, or special circumstances (such as, personal hardship), all
as determined from time to time by the Committee. Employees can request
an exception by submitting a written request to the Code of Ethics
Officer.

Rule 8: Good Until Canceled Orders

Good Until Canceled (GTC) Orders and Limit Orders are prohibited.

Any order not executed on the day of pre-clearance must be resubmitted
for pre-clearance before being executed on a subsequent day. "Good until
canceled" or "limit" orders are prohibited because of the potential
failure to pre-clear.

Rule 9: Excessive Trading

Putnam employees are strongly discouraged from engaging in excessive
trading for their personal accounts. Beginning with the fourth quarter
of 2004, employees will be prohibited from making more than 25 trades in
individual securities in any given quarter. Excessive trading within
Putnam open-end mutual funds is prohibited.


COMMENTS

* Although a Putnam employee's excessive trading may not itself
constitute a conflict of interest with Putnam clients, Putnam believes
that its clients' confidence in Putnam will be enhanced and the
likelihood of Putnam achieving better investment results for its clients
over the long term will be increased if Putnam employees rely on their
investment-- as opposed to trading-- skills in transactions for their
own account. Moreover, excessive trading by a Putnam employee for his or
her own account diverts an employee's attention from the responsibility
of servicing Putnam clients, and increases the possibilities for
transactions that are in actual or apparent conflict with Putnam client
transactions. Short-term trading is strongly discouraged while employees
are encouraged to take a long-term view.

* Employees should be aware that their trading activity is closely
monitored. Ten trades or more per quarter will be discouraged and will
warrant a review memo. Activity exceeding 25 trades per quarter will be
prohibited by the Code of Ethics Oversight Committee. Sanctions will be
imposed such as a trading ban or a more stringent sanction may be
determined at the discretion of the Committee. Different rules apply
with respect to trading in shares of Putnam open-end mutual funds. See
Section I. B, Rule 7 above.

C. Discouraged Transactions

Rule 1

Putnam employees are strongly discouraged from engaging in writing
(selling) naked options for their personal accounts.

Naked option transactions are particularly dangerous, because a Putnam
employee may be prevented by the restrictions in this Code of Ethics
from covering the naked option at the appropriate time. All employees
should keep in mind the limitations on their personal securities trading
imposed by this Code when contemplating such an investment strategy.
Engaging in naked options transactions on the basis of material,
nonpublic information is prohibited. See Appendix A, Policy Statement
Concerning Insider Trading Prohibitions.


EXCEPTIONS

None.

D. Exempted Transactions

Rule 1

Transactions that are involuntary on the part of a Putnam employee are
exempt from the prohibitions set forth in Sections I.A., I.B., and I.C.


EXCEPTIONS

None.

COMMENTS

* This exemption is based on categories of conduct that the Securities
and Exchange Commission does not consider "abusive."

* Examples of involuntary personal securities transactions include:

(a) Sales out of the brokerage account of a Putnam employee as a result
of bona fide margin call, provided that withdrawal of collateral by the
Putnam employee within the ten days previous to the margin call was not
a contributing factor to the margin call;

(b) Purchases arising out of an automatic dividend reinvestment program
of an issuer of a publicly traded security.

* Transactions by a trust in which the Putnam employee (or a member of
his immediate family) holds a beneficial interest, but for which the
employee has no direct or indirect influence or control with respect to
the selection of investments, are involuntary transactions. In addition,
these transactions do not fall within the definition of "personal
securities transactions." See Definitions.

* A good-faith belief on the part of the employee that a transaction was
involuntary will not be a defense to a violation of the Code of Ethics.
In the event of confusion as to whether a particular transaction is
involuntary, the burden is on the employee to seek a prior written
determination of the applicability of this exemption. The procedures for
obtaining such a determination appear in Section VII, Part 4.

Rule 2

Transactions that have been determined in writing by the Code of Ethics
Officer before the transaction occurs to be no more than remotely
harmful to Putnam clients because the transaction would be very unlikely
to affect a highly institutional market, or because the transaction is
clearly not related economically to the securities to be purchased,
sold, or held by a Putnam client, are exempt from the prohibitions set
forth in Sections I.A., I.B., and I.C.


IMPLEMENTATION

An employee may seek an ad-hoc exemption under this Rule by following
the procedures in Section VII, Part 4.


COMMENTS

* This exemption is also based upon categories of conduct that the
Securities and Exchange Commission does not consider "abusive."

* The burden is on the employee to seek a prior written determination
that the proposed transaction meets the standards for an ad hoc
exemption set forth in this Rule.


SECTION II
Additional Special Rules for Personal Securities Transactions of Access
Persons and Certain Investment Professionals

Access Persons (including all investment professionals and other
employees as defined on page vii)

Rule 1: 60-Day Rule

No Access Person shall purchase and then sell at a profit, or sell and
then repurchase at a lower price, any security or related derivative
security within 60 calendar days.


EXCEPTIONS

None, unless prior written approval from the Code of Ethics Officer is
obtained. Exceptions may be granted on a case-by-case basis when no
abuse is involved and the equities of the situation support an
exemption. For example, although an Access Person may buy a stock as a
long-term investment, that stock may have to be sold involuntarily due
to unforeseen activity such as a merger.


IMPLEMENTATION

A. The 60-Day Rule applies to all Access Persons, as defined in the
Definitions section of the Code.

B. Calculation of whether there has been a profit is based upon the
market prices of the securities. The calculation is not net of
commissions or other sales charges.

C. As an example, an Access Person would not be permitted to sell a
security at $12 that he purchased within the prior 60 days for $10.
Similarly, an Access Person would not be permitted to purchase a
security at $10 that she had sold within the prior 60 days for $12.


COMMENTS

* The prohibition against short-term trading profits by Access Persons
is designed to minimize the possibility that they will capitalize
inappropriately on the market impact of trades involving a client
portfolio about which they might possibly have information.

* Although chief investment officers, portfolio managers, and analysts
may sell securities at a profit within 60 days of purchase in order to
comply with the requirements of the 7-Day Rule applicable to them
(described below), the profit will have to be disgorged to charity under
the terms of the 7-Day Rule.

* Effective in the fourth quarter of 2004, the 60-Day Rule will become a
Black Out Rule. An Access Person cannot trade a security within 60 days
regardless of tax lot election.

Certain Investment Professionals

Rule 2: 7-Day Rule

(a) Portfolio Managers: Before a portfolio manager (including a chief
investment officer with respect to an account he manages) places an
order to buy a security for any Putnam client portfolio that he manages,
he shall sell any such security or related derivative security purchased
in a transaction for his personal account within the preceding seven
calendar days.

(b) Comanagers: Before a portfolio manager places an order to buy a
security for any Putnam client he manages, his comanager shall sell any
such security or related derivative security purchased in a transaction
for his personal account within the preceding seven calendar days.

(c) Analysts: Before an analyst makes a buy recommendation for a
security (including designation of a security for inclusion in the
portfolio of the Putnam Research Fund), he shall sell any such security
or related derivative security purchased in a transaction for his
personal account within the preceding seven calendar days.


COMMENTS

* This Rule applies to portfolio managers (including chief investment
officers (CIO) with respect to accounts they manage) in connection with
any purchase (no matter how small) in any client account managed by that
portfolio manager or CIO (even so-called "clone accounts"). In
particular, it should be noted that the requirements of this Rule also
apply with respect to purchases in client accounts, including "clone
accounts," resulting from "cash flows." To comply with the requirements
of this Rule, it is the responsibility of each portfolio manager or CIO
to be aware of the placement of all orders for purchases of a security
by client accounts that he or she manages for seven days following the
purchase of that security for his or her personal account.

* An investment professional who must sell securities to be in
compliance with the 7-Day Rule must absorb any loss and disgorge to
charity any profit resulting from the sale. The recipient charity will
be chosen by the Code of Ethics Officer.

* This Rule is designed to avoid even the appearance of a conflict of
interest between an investment professional and a Putnam client. A
greater burden is placed on these professionals given their positions in
the organization. Transactions executed for the employee's personal
account must be conducted in a manner consistent with the Code of Ethics
and in such a manner as to avoid any actual or perceived conflict of
interest or any abuse of the employee's position of trust and
responsibility.

* "Portfolio manager" is used in this Section as a functional label, and
is intended to cover any employee with authority to authorize a trade on
behalf of a Putnam client, whether or not such employee bears the title
"portfolio manager." "Analyst" is also used in this Section as a
functional label, and is intended to cover any employee who is not a
portfolio manager but who may make recommendations regarding investments
for Putnam clients.


EXCEPTIONS

None.

Rule 3: Blackout Rule

(a) Portfolio Managers: No portfolio manager (including a chief
investment officer with respect to an account she manages) shall: (i)
sell any security or related derivative security for her personal
account until seven calendar days have elapsed since the most recent
purchase of that security or related derivative security by any Putnam
client portfolio she manages or comanages; or (ii) purchase any security
or related derivative security for her personal account until seven
calendar days have elapsed since the most recent sale of that security
or related derivative security from any Putnam client portfolio that she
manages or comanages.

(b) Analysts: No analyst shall: (i) sell any security or related
derivative security for his personal account until seven calendar days
have elapsed since his most recent buy recommendation for that security
or related derivative security (including designation of a security for
inclusion in the portfolio of the Putnam Research Fund); or (ii)
purchase any security or related derivative security for his personal
account until seven calendar days have elapsed since his most recent
sell recommendation for that security or related derivative security
(including the removal of a security from the portfolio of the Putnam
Research Fund).


COMMENTS

* This Rule applies to portfolio managers (including chief investment
officers with respect to accounts they manage) in connection with any
purchase (no matter how small) in any client account managed by that
portfolio manager or CIO (even clone accounts). In particular, it should
be noted that the requirements of this rule also apply with respect to
transactions in client accounts, including clone accounts, resulting
from cash flows. In order to comply with the requirements of this Rule,
it is the responsibility of each portfolio manager and CIO to be aware
of all transactions in a security by client accounts that he or she
manages that took place within the seven days preceding a transaction in
that security for his or her personal account.

* This Rule is designed to prevent a Putnam portfolio manager or analyst
from engaging in personal investment conduct that appears to be counter
to the investment strategy she is pursuing or recommending on behalf of
a Putnam client.

* Trades by a Putnam portfolio manager for her personal account in the
"same direction" as the Putnam client portfolio she manages, and trades
by an analyst for his personal account in the same direction as his
recommendation, do not present the same danger, so long as any same
direction trades do not violate other provisions of the Code or the
Policy Statements.


EXCEPTIONS

None.

Rule 4: Contra Trading Rule

(a) Portfolio Managers: No portfolio manager shall, without prior
clearance, sell out of his personal account securities or related
derivative securities held in any Putnam client portfolio that he
manages or comanages

(b) Chief Investment Officers: No chief investment officer shall,
without prior clearance, sell out of his personal account securities or
related derivative securities held in any Putnam client portfolio
managed in his investment group.


EXCEPTIONS

None, unless prior clearance and written approval are given.

IMPLEMENTATION

A. Individuals Authorized to Give Approval. Prior to engaging in any
such sale, a portfolio manager shall seek approval, in writing, of the
proposed sale. In the case of a portfolio manager or director, prior
written approval of the proposed sale shall be obtained from a chief
investment officer to whom he reports or, in his absence, another chief
investment officer. In the case of a chief investment officer, prior
written approval of the proposed sale shall be obtained from another
chief investment officer. In addition to the foregoing, prior written
approval must also be obtained from the Code of Ethics Officer.

B. Contents of Written Approval. In every instance, the written approval
form attached as Appendix C (or such other form as the Code of Ethics
Officer shall designate) shall be used. The written approval should be
signed by the chief investment officer giving approval and dated the
date such approval was given, and shall state, briefly, the reasons why
the trade was allowed and why the investment conduct pursued by the
portfolio manager, director, or chief investment officer was deemed
inappropriate for the Putnam client account controlled by the individual
seeking to engage in the transaction for his personal account. Such
written approval shall be sent by the chief investment officer approving
the transaction to the Code of Ethics Officer, for her approval, within
24 hours or as promptly as circumstances permit. Approvals obtained
after a transaction has been completed or while it is in process will
not satisfy the requirements of this Rule.


COMMENT

This Rule, like Rule 3 of this Section, is designed to prevent a Putnam
portfolio manager from engaging in personal investment conduct that
appears to be counter to the investment strategy that he is pursuing on
behalf of a Putnam client.

Rule 5

No portfolio manager shall cause, and no analyst shall recommend, a
Putnam client to take action for the portfolio manager's or analyst's
own personal benefit.


EXCEPTIONS

None.

COMMENTS

* A portfolio manager who trades in, or an analyst who recommends,
particular securities for a Putnam client account in order to support
the price of securities in his personal account, or who "front runs" a
Putnam client order is in violation of this Rule. Portfolio managers and
analysts should be aware that this Rule is not limited to personal
transactions in securities (as that word is defined in Definitions).
Thus, a portfolio manager or analyst who front runs a Putnam client
purchase or sale of obligations of the U.S. government is in violation
of this Rule, although U.S. government obligations are excluded from the
definition of security.

* This Rule is not limited to instances when a portfolio manager or
analyst has malicious intent. It also prohibits conduct that creates an
appearance of impropriety. Portfolio managers and analysts who have
questions about whether proposed conduct creates an appearance of
impropriety should seek a prior written determination from the Code of
Ethics Officer, using the procedures described in Section VII, Part 3.


SECTION III

General Rules for All Employees

Rule 1: Compliance with All Laws, Regulations and Policies

All employees must comply with applicable laws and regulations as well
as company policies. This includes tax, anti-trust, political
contribution, and international boycott laws. In addition, no employee
at Putnam may engage in fraudulent conduct of any kind.


EXCEPTIONS

None.

COMMENTS

* Putnam may report to the appropriate legal authorities conduct by
Putnam employees that violates this Rule.

* It should also be noted that the U.S. Foreign Corrupt Practices Act
makes it a criminal offense to make a payment or offer of payment to any
non-U.S. governmental official, political party, or candidate to induce
that person to affect any governmental act or decision, or to assist
Putnam's obtaining or retaining business.

Rule 2: Conflicts of Interest

No Putnam employee shall conduct herself in a manner, which is contrary
to the interests of, or in competition with, Putnam or a Putnam client,
or which creates an actual or apparent conflict of interest with a
Putnam client.


EXCEPTIONS

None.

COMMENTS

* This Rule is designed to recognize the fundamental principle that
Putnam employees owe their chief duty and loyalty to Putnam and Putnam
clients.

* It is expected that a Putnam employee who becomes aware of an
investment opportunity that she believes is suitable for a Putnam client
who she services will present it to the appropriate portfolio manager,
prior to taking advantage of the opportunity herself.

Rule 3: Gifts and Entertainment Policy

No Putnam employee shall accept anything of material value from any
broker-dealer, financial institution, corporation or other entity, any
existing or prospective supplier of goods or services with a business
relationship to Putnam, or any company or other entity whose securities
are held in or are being considered as investments for the Putnam funds,
or any other client account. Included are gifts, favors, preferential
treatment, special arrangements, or access to special events.


COMMENTS

This Rule is intended to permit the acceptance of only proper types of
customary and limited business amenities.

A Putnam employee may not, under any circumstances, accept anything that
could create the appearance of any kind of conflict of interest. For
example, acceptance of any consideration is prohibited if it would
create the appearance of a reward or inducement for conducting Putnam
business either with the person providing the gift or his employer.


IMPLEMENTATION

A. Gifts. An employee may not accept small gifts with an aggregate value
of more than $100 in any year from any one source. Any Putnam employee
who is offered or receives an item exceeding $100 in value is prohibited
by this Rule and must report the details to the Code of Ethics Officer.
Any entertainment event provided to an employee where the host is not in
attendance is treated as a gift and is subject to the $100 per year per
source limit.

B. Entertainment. Putnam's rules are designed to permit reasonable,
ordinary business entertainment, but prohibit any events, which may be
perceived as extravagant or involving lavish expenditures.

1. Occasional lunches, dinners, cocktail parties, or comparable
gatherings conducted for business purposes are permitted.

For example, occasional attendance at group functions sponsored by sell
side firms is permitted where the function relates to investments or
other business activity. Occasional attendance at these functions is not
required to be counted against the limits described in paragraph 2(b)
below.

2. Other entertainment events, such as, sporting events, theater,
movies, concerts, or other forms of entertainment conducted for business
purposes, are permitted only under the following conditions:

(i) The host must be present for the event.

(ii) The location of the event must be in the metropolitan area in which
the office of the employee is located.

(iii) Spouses or other family members of the employee may not attend the
entertainment event or any meals before or after the entertainment
event.

(iv) The value of the entertainment event provided to the employee may
not exceed $150, not including the value of any meals that may be
provided to the employee before or after the event.

Acceptance of entertainment events having a market value materially
exceeding the face value of the entertainment including, for example,
attendance at sporting event playoff games, is prohibited. This
prohibition applies even if the face value of tickets to the events is
$150 or less or when the Putnam employee offers to pay for the tickets.
If there is any ambiguity about whether to accept an entertainment event
in these circumstances, please consult the Code of Ethics Officer.

(v) The employee may not accept entertainment events under this
provision (B)(2) more than six times a year and not more than two times
in any year from any single source.

(vi) The Code of Ethics Officer may grant exceptions to these rules. For
example, it may be appropriate for an employee attending a legitimate
conference in a location away from the office to attend a business
entertainment event in that location. All exceptions must be approved in
advance by written request to the Code of Ethics Officer.

3. Any employee attending any entertainment event under (B)(1) or (B)(2)
above must file a Report of Entertainment Form (attached as Appendix E)
with the Code of Ethics Officer within 10 days following the date of the
entertainment event. Failure to file the notice is a violation of the
Code of Ethics.

4. Meals and entertainment, which are part of the regular program at an
investment conference (i.e., open to all participants) are not subject
to the limits of this section (B)(2) above.

C. Among the items that are prohibited are:

1. Any entertainment event attendance, which would reflect badly on
Putnam as a firm of the highest fiduciary and ethical standards. For
example, events involving adult entertainment or gambling must be
avoided.

2. Entertainment involving travel away from the metropolitan area in
which the employee is located. Even in the event an exception is granted
as contemplated by (B)(2)(vi) above, payment by a third party of the
cost of transportation to a location outside the employee's metropolitan
area, lodging while in another location, and any meals not specifically
approved by the Code of Ethics officer, are prohibited;

3. Personal loans to a Putnam employee on terms more favorable than
those generally available for comparable credit standing and collateral;
and

4. Preferential brokerage or underwriting commissions or spreads or
allocations of shares or interests in an investment for the personal
account of a Putnam employee; and

5. Cash or cash equivalents

D. As with any of the provisions of the Code of Ethics, a sincere belief
by the employee that he was acting in accordance with the requirements
of this Rule will not satisfy his obligations under the Rule. Therefore,
an employee who is in doubt concerning the propriety of any gift or
favor should seek a prior written determination from the Code of Ethics
Officer, as provided in number 3 of Section VII.

E. No Putnam employee may solicit any gift or entertainment from any
person, even if the gift or entertainment, if unsolicited, would be
permitted.

F. The Rule does not prohibit employees on business travel from using
local transportation and arrangements customarily supplied by brokers or
similar entities. For example, it is customary for brokers in developing
markets to make local transportation arrangements. These arrangements
are permitted so long as the expense of lodging and air travel are paid
by Putnam.

Rule 4: Anti-bribery/Kickback Policy

No Putnam employee shall pay, offer, or commit to pay any amount of
consideration which might be or appear to be a bribe or kickback in
connection with Putnam's business.


EXCEPTIONS

None.

COMMENT

Although the rule does not specifically address political contributions
(which are described in Rule 5 below), Putnam employees should be aware
that it is against corporate policy to use company assets to fund
political contributions of any sort, even where such contributions may
be legal. No Putnam employee should offer or agree to make any political
contributions (including political dinners and similar fundraisers) on
behalf of Putnam, and no employee will be reimbursed by Putnam for such
contributions made by the employee personally.

Rule 5: Political Contributions/Solicitations Policy

No contributions may be made with corporate funds to any political party
or campaign, whether directly or by reimbursement to an employee for the
expense of such a contribution. No Putnam employee shall solicit any
charitable, political, or other contributions using Putnam letterhead or
making reference to Putnam in the solicitation. No Putnam employee shall
personally solicit any such contribution while on Putnam business.


EXCEPTIONS

None.

COMMENTS

* Putnam has established a political action committee (PAC) that
contributes to worthy candidates for political office. Any request
received by a Putnam employee for a political contribution must be
directed to Putnam's Legal and Compliance Department.

* This rule prohibits solicitation on personal letterhead by Putnam
employees except as approved by the Code of Ethics Officer.

* Certain officers and employees of Putnam Retail Management and other
employees involved in Putnam's College Advantage Section 529 Plan with
Ohio Tuition Trust Authority are subject to special rules on political
contributions. For questions on these requirements, please call the Code
of Ethics Administrator.

Rule 6: Confidentiality of Putnam Business Information

No unauthorized disclosure may be made by any employee or former
employee of any trade secrets or proprietary information of Putnam or of
any confidential information. No information regarding any Putnam client
portfolio, actual or proposed securities trading activities of any
Putnam client, or Putnam research shall be disclosed outside the Putnam
organization unless doing so has a valid business purpose and is in
accord with any relevant procedures established by Putnam relating to
such disclosures.


COMMENT

All information about Putnam and Putnam clients is strictly
confidential. Putnam research information should not be disclosed
without proper approval and never for personal gain.

Rule 7: Roles At Other Entities

No Putnam employee shall serve as officer, employee, director, trustee,
or general partner of a corporation or entity other than Putnam, without
prior approval of the Code of Ethics Officer. Requests for a role at a
publicly-traded company will be closely reviewed and permission will be
granted on an ad-hoc basis.


EXCEPTION

Charitable or Non-profit Exception. This Rule shall not prevent any
Putnam employee from serving as officer, director, or trustee of a
charitable or not-for-profit institution, provided that the employee
abides by the Code of Ethics and the Policy Statements with respect to
any investment activity for which she has any discretion or input as
officer, director, or trustee. The pre-clearance and reporting
requirements of the Code of Ethics do not apply to the trading
activities of such charitable or not-for-profit institutions for which
an employee serves as an officer, director, or trustee unless the
employee is responsible for day-to-day portfolio management of the
account.


COMMENTS

* This Rule is designed to ensure that Putnam cannot be deemed an
affiliate of any issuer of securities by virtue of service by one of its
officers or employees as director or trustee.

* Positions with public companies are especially problematic and will
normally not be approved.

* Certain charitable or not-for-profit institutions have assets (such as
endowment funds or employee benefit plans) which require prudent
investment. To the extent that a Putnam employee (because of her
position as officer, director, or trustee of an outside entity) is
charged with responsibility to invest such assets prudently, she may not
be able to discharge that duty while simultaneously abiding by the
spirit of the Code of Ethics and the Policy Statements. Employees are
cautioned that they should not accept service as an officer, director,
or trustee of an outside charitable or not-for-profit entity where such
investment responsibility is involved, without seriously considering
their ability to discharge their fiduciary duties with respect to such
investments.

Rule 8: Role as Trustee or Fiduciary Outside of Putnam

No Putnam employee shall serve as a trustee, executor, custodian, any
other fiduciary, or as an investment advisor or counselor for any
account outside Putnam.


EXCEPTIONS

A. Charitable or Religious Exception. This Rule shall not prevent any
Putnam employee from serving as fiduciary with respect to a religious or
charitable trust or foundation, so long as the employee abides by the
spirit of the Code of Ethics and the Policy Statements with respect to
any investment activity over which he has any discretion or input. The
pre-clearance and reporting requirements of the Code of Ethics do not
apply to the trading activities of such a religious or charitable trust
or foundation unless the employee is responsible for day-to-day
portfolio management of the account.

B. Family Trust or Estate Exception. This Rule shall not prevent any
Putnam employee from serving as fiduciary with respect to a family trust
or estate, so long as the employee abides by all of the Rules of the
Code of Ethics with respect to any investment activity over which he has
any discretion.


COMMENT

The roles permissible under this Rule may carry with them the obligation
to invest assets prudently. Once again, Putnam employees are cautioned
that they may not be able to fulfill their duties in that respect while
abiding by the Code of Ethics and the Policy Statements.

Rule 9: Investment Clubs

No Putnam employee may be a member of any investment club.

EXCEPTIONS

None.

COMMENT

This Rule guards against the danger that a Putnam employee may be in
violation of the Code of Ethics and the Policy Statements by virtue of
his personal securities transactions in or through an entity that is not
bound by the restrictions imposed by this Code of Ethics and the Policy
Statements. Please note that this restriction also applies to the spouse
of a Putnam employee and any relatives of a Putnam employee living in
the same household as the employee, as their transactions are covered by
the Code of Ethics (see page vii).

Rule 10: Business Negotiations For Putnam

No Putnam employee may become involved in a personal capacity in
consultations or negotiations for corporate financing, acquisitions, or
other transactions for outside companies (whether or not held by any
Putnam client), nor negotiate nor accept a fee in connection with these
activities without obtaining the prior written permission of the
president of Putnam Investments.


EXCEPTIONS

None.

Rule 11: Accurate Records

No employee may create, alter or destroy (or participate in the
creation, alteration or destruction of) any record that is intended to
mislead anyone or to conceal anything that is, or is reasonably believed
to be, improper. In addition, all employees responsible for the
preparation, filing, or distribution of any regulatory filings or public
communications must ensure that such filings or communications are
timely, complete, fair, accurate, and understandable.


EXCEPTIONS

None.

COMMENTS

* In many cases, this is not only a matter of company policy and ethical
behavior but also required by law. Our books and records must accurately
reflect the transactions represented and their true nature. For example,
records must be accurate as to the recipient of all payments; expense
items, including personal expense reports, must accurately reflect the
true nature of the expense. No unrecorded fund or asset shall be
established or maintained for any reason.

* All financial books and records must be prepared and maintained in
accordance with Generally Accepted Accounting Principles and Putnam's
existing accounting controls, to the extent applicable.

Rule 12: Interest in Entities Doing Business with Putnam

No employee shall have any direct or indirect (including by a family
member or close relative) personal financial interest (other than normal
investments not material to the employee in the entity's publicly-traded
securities) in any business, with which Putnam has dealings unless such
interest is disclosed and approved by the Code of Ethics Officer.

Rule 13: Affiliated Entities

No employee shall, with respect to any affiliate of Putnam that provides
investment advisory services and is listed below in Comment 4 to this
Rule, as revised from time to time (each a Non-Putnam affiliate or NPA),

(a) Directly or indirectly seek to influence the purchase, retention, or
disposition of, or exercise of voting consent, approval or similar
rights with respect to, any portfolio security in any account or fund
advised by the NPA and not by Putnam,

(b) Transmit any information regarding the purchase, retention or
disposition of, or exercise of voting, consent, approval, or similar
rights with respect to, any portfolio security held in a Putnam or NPA
client account to any personnel of the NPA,

(c) Transmit any trade secrets, proprietary information, or confidential
information of Putnam to the NPA unless doing so has a valid business
purpose and is in accord with any relevant procedures established by
Putnam relating to such disclosures,

(d) Use confidential information or trade secrets of the NPA for the
benefit of the employee, Putnam, or any other NPA, or

(e) Breach any duty of loyalty to the NPA derived from the employee's
service as a director or officer of the NPA.


COMMENTS

* Sections (a) and (b) of the Rule are designed to help ensure that the
portfolio holdings of Putnam clients and clients of the NPA need not be
aggregated for purposes of determining beneficial ownership under
Section 13(d) of the Securities Exchange Act or applicable regulatory or
contractual investment restrictions that incorporate such definition of
beneficial ownership. Persons who serve as directors or officers of both
Putnam and an NPA should take care to avoid even inadvertent violations
of Section (b). Section (a) does not prohibit a Putnam employee who
serves as a director or officer of the NPA from seeking to influence the
modification or termination of a particular investment product or
strategy in a manner that is not directed at any specific securities.
Sections (a) and (b) do not apply when a Putnam affiliate serves as an
advisor or sub-advisor to the NPA or one of its products, in which case
normal Putnam aggregation rules apply.

* As a separate entity, any NPA may have trade secrets or confidential
information that it would not choose to share with Putnam. This choice
must be respected.

* When Putnam employees serve as directors or officers of an NPA, they
are subject to common law duties of loyalty to the NPA, despite their
Putnam employment. In general, this means that when performing their
duties as NPA directors or officers, they must act in the best interest
of the NPA and its shareholders. Putnam's Legal and Compliance
Department will assist any Putnam employee who is a director or officer
of an NPA and has questions about the scope of his or her
responsibilities to the NPA.

* Entities that are currently non-Putnam affiliates within the scope of
this Rule are: Cisalpina Gestioni, S.p.A., Nissay Asset Management Co.,
Ltd., Thomas H. Lee Partners, L.P., Ampega Asset Management, GMBH, and
Sceptre Investment Counsel, Ltd.

Rule 14: Computer System/Network Policies

No employee shall use computer hardware, software, data, Internet,
electronic mail, voice mail, electronic messaging (e-mail or cc: Mail),
or telephone communications systems in a manner that is inconsistent
with their use as set forth in policy statements governing their use
that are adopted from time to time by Putnam. No employee shall
introduce a computer virus or computer code that may result in damage to
Putnam's information or computer systems.


COMMENT

Putnam's policy statements relating to these matters are contained in
the Computer System and Network Responsibilities section of the
Employment Issues category within the Employee Handbook. The online
Employee Handbook is located online at www.ibenefitcenter.com under
Policies and Procedures under the @Putnam tab.


EXCEPTIONS

None.

Rule 15: AIMR Code of Ethics

All employees must follow and abide by the spirit of the Code of Ethics
and the Standards of Professional Conduct of the Association of
Investment Management and Research (AIMR). The texts of the AIMR Code of
Ethics and Standards of Professional Conduct are set forth in Exhibit D.


EXCEPTIONS

None.

Rule 16: Privacy Policy

Except as provided below, no employee may disclose to any outside
organization or person any nonpublic personal information about any
individual who is a current or former shareholder of any Putnam retail
or institutional fund, or current or former client of a Putnam company.
All employees shall follow the security procedures as established from
time to time by a Putnam company to protect the confidentiality of all
shareholder and client account information.

Except as Putnam's Legal and Compliance Department may expressly
authorize, no employee shall collect any nonpublic personal information
about a prospective or current shareholder of a Putnam Fund or
prospective or current client of a Putnam company, other than through an
account application (or corresponding information provided by the
shareholder's financial representative) or in connection with executing
shareholder or client transactions, nor shall any information be
collected other than the following: name, address, telephone number,
Social Security number, and investment, broker, and transaction
information.


EXCEPTIONS

A. Putnam Employees. Nonpublic personal information may be disclosed to
Putnam employees in connection with processing transactions or
maintaining accounts for shareholders of a Putnam fund and clients of a
Putnam company, to the extent that access to such information is
necessary to the performance of that employee's job functions.

B. Shareholder Consent Exception. Nonpublic personal information about a
shareholder's or client's account may be provided to a non-Putnam
organization at the specific request of the shareholder or client or
with the shareholder's or client's prior written consent.

C. Broker or Advisor Exception. Nonpublic personal information about a
shareholder's or client's account may be provided to the shareholder's
or client's broker of record.

D. Third-Party Service Provider Exception. Nonpublic personal
information may be disclosed to a service provider that is not
affiliated with a Putnam fund or Putnam company only when such
disclosure is necessary for the service provider to perform the specific
services contracted for, and only (a) if the service provider executes
Putnam's standard confidentiality agreement, or (b) pursuant to an
agreement containing a confidentiality provision that has been approved
by the Legal and Compliance Department. Examples of such service
providers include proxy solicitors and proxy vote tabulators, mail
services, and providers of other administrative services, and
Information Services Division consultants who have access to nonpublic
personal information.


COMMENTS

* Nonpublic personal information is any information that personally
identifies a shareholder of a Putnam fund or client of a Putnam company
and is not derived from publicly available sources. This privacy policy
applies to shareholders or clients who are individuals, not
institutions. However, as a general matter, all information that we
receive about a shareholder of a Putnam fund or client of a Putnam
company shall be treated as confidential. No employee may sell or
otherwise provide shareholder or client lists or any other information
relating to a shareholder or client to any marketing organization.

* All Putnam employees with access to shareholder or client account
information must be trained in and follow Putnam's security procedures
designed to safeguard that information from unauthorized use. For
example, a telephone representative must be trained in and follow
Putnam's security procedures to verify the identity of a caller
requesting account information.

* Any questions regarding this privacy policy should be directed to
Putnam's Legal and Compliance Department. A violation of this policy
will be subject to the sanctions imposed for violations of Putnam's Code
of Ethics.

* Employees must report any violation of this policy or any possible
breach of the confidentiality of client information (whether intentional
or accidental) to the managing director in charge of the employee's
business unit. Managing directors who are notified of such a violation
or possible breach must immediately report it in writing to Putnam's
chief compliance officer and, in the event of a breach of computerized
data, Putnam's chief technology officer.

Rule 17: Anti-money Laundering Policy

No employee may engage in any money laundering activity or facilitate
any money-laundering activity through the use of any Putnam account or
client account. Any situations giving rise to a suspicion that attempted
money laundering may be occurring in any account must be reported
immediately to the managing director in charge of the employee's
business unit. Managing directors who are notified of such a suspicion
of money laundering activity must immediately report it in writing to
Putnam's chief compliance officer and chief financial officer.

Rule 18: Record Retention

All employees must comply with the record retention requirements
applicable to the business unit. Employees should check with their
managers or the chief administrative officer of their division to
determine what record retention requirements apply to their business
unit.


SECTION IV

Special Rules for Officers and Employees of Putnam Investments Limited

Rule 1

In situations subject to Section I.A., Rule 1 (Restricted List Personal
Securities Transactions, the Putnam Investments Limited (PIL) employee
must obtain clearance not only as provided in that rule, but also from
PIL's Compliance Officer or her designee, who must approve the
transaction before any trade is placed and record the approval.


EXCEPTIONS

None.

IMPLEMENTATION

Putnam's Code of Ethics Administrator in Boston (the Boston
Administrator) has also been designated the Assistant Compliance Officer
of PIL and has been delegated the right to approve or disapprove
personal securities transactions in accordance with the requirements of
Section I.A. Therefore, approval from the Code of Ethics Administrator
for PIL employees to make personal securities investments constitutes
approval under the Code of Ethics and also for purposes of compliance
with the Financial Services Authority, the U.K. self-regulatory
organization that regulates PIL.

The position of London Code of Ethics Administrator (the London
Administrator) has also been created (Jane Barlow is the current London
Administrator). All requests for clearances must be made by e-mail to
the Boston Administrator copying the London Administrator. The e-mail
must include the number of shares to be bought or sold and the name of
the broker(s) involved. Where time is of the essence clearances may be
made by telephone to the Boston Administrator but they must be followed
up by e-mail.

Both the Boston and London Administrators will maintain copies of all
clearances for inspection by senior management and regulators.

Rule 2

No PIL employee may trade with any broker or dealer unless that broker
or dealer has sent a letter to the London Administrator agreeing to
deliver copies of trade confirmations and statements to PIL. No PIL
employee may enter into any margin or any other special dealing
arrangement with any broker-dealer without the prior written consent of
the PIL compliance officer.


EXCEPTIONS

None.

IMPLEMENTATION

PIL employees will be notified separately of this requirement once a
year by the PIL compliance officer, and are required to provide an
annual certification of compliance with the Rule.

All PIL employees must inform the London Administrator of the names of
all brokers and dealers with whom they trade prior to trading. The
London Administrator will send a letter to the broker(s) in question
requesting them to agree to deliver copies of confirms to PIL. The
London Administrator will forward copies of the confirms to the Boston
Administrator. PIL employees may trade with a broker only when the
London Administrator has received the signed agreement from that broker.

Rule 3

For purposes of the Code of Ethics, including Putnam's Policy Statement
on Insider Trading Prohibitions, PIL employees must also comply with
Part V of the Criminal Justice Act 1993 on insider dealing.


EXCEPTIONS

None.

IMPLEMENTATION

To ensure compliance with UK insider dealing legislation, PIL employees
must observe the relevant procedures set forth in PIL's Compliance
Manual, a copy of which is sent to each PIL employee, and sign an annual
certification as to compliance.


SECTION V

Reporting Requirements for All Employees

Reporting of Personal Securities Transactions

Rule 1

Each Putnam employee shall ensure that copies of all confirmations for
securities transactions for his personal brokerage accounts, and,
beginning in the fourth quarter 2004, brokerage account statements are
sent to the Putnam Compliance Department's (Code of Ethics
Administrator). (For the purpose of this Rule, securities shall also
include ETFs, futures, and other derivatives on broad-based market
indexes excluded from the pre-clearance requirement.) Statements and
confirmations are required for Putnam funds not held at PPA or in a
Putnam retirement plan, as well as for U.S. mutual funds sub-advised by
Putnam.


EXCEPTION

None.

IMPLEMENTATION

A. Putnam employees must instruct their broker-dealers to send
statements and confirmations to Putnam and must follow up with the
broker-dealer on a reasonable basis to ensure that the instructions are
being followed. For brokerage accounts, Putnam employees should contact
the Code of Ethics Administrator to obtain a letter from Putnam
authorizing the setting up of a personal brokerage account.

B. Statements and confirmations should be submitted to the Code of
Ethics Administrator.

C. Specific procedures apply to employees of PIL. Employees of PIL
should contact the London Code of Ethics Administrator.

D. Failure of a broker-dealer to comply with the instructions of a
Putnam employee to send confirmations shall be a violation by the Putnam
employee of this Rule. Similarly, failure by an employee to report the
existence of a personal account (and, if the account is opened after
joining Putnam, failure to obtain proper authorization to establish the
account) shall be a violation of this Rule.

E. Statements and confirmations must also be sent for members of an
employees' immediate family, including statements received with respect
to a family member's 401(k) plan at another employer.


COMMENTS

* Transactions for personal accounts is defined broadly to include more
than transaction in accounts under an employee's own name. See
Definitions.

* Statements and confirmations are required for all personal securities
transactions, whether or not exempted or excepted by this Code.

* To the extent that a Putnam employee has investment authority over
securities transactions of a family trust or estate, confirmations of
those transactions must also be made, unless the employee has received a
prior written exception from the Code of Ethics Officer.

Rule 2

Every Access Person shall file a quarterly report, within ten calendar
days of the end of each quarter, recording all purchases and sales of
any securities for personal accounts as defined in the Definitions. (For
the purpose of this Rule, "securities" shall include exchange traded
funds (ETF), futures, and any option on a security or securities index,
including broad-based market indexes excluded from the pre-clearance
requirement and also includes transactions in Putnam open-end funds if
the account for the Putnam funds is not held at PPA or in a Putnam
retirement plan and for transactions in U.S. mutual funds sub-advised by
Putnam.)


EXCEPTIONS

None.

IMPLEMENTATION

All employees required to file such a report will receive by e-mail a
blank form at the end of the quarter from the Code of Ethics
Administrator. The form will specify the information to be reported. The
form shall also contain a representation that employees have complied
fully with all provisions of the Code of Ethics.


COMMENTS

* The date for each transaction required to be disclosed in the
quarterly report is the trade date for the transaction, not the
settlement date.

* If the requirement to file a quarterly report applies to you and you
fail to report within the required 10-day period, salary increases and
bonuses will be reduced in accordance with guidelines stated in the
form. It is the responsibility of the employee to request an early
report if he has knowledge of a planned absence, i.e., vacation or
business trip.

Reporting of Personal Securities Holdings

Rule 3

Access Persons must disclose all personal securities holdings to the
Code of Ethics Officer upon commencement of employment within ten
calendar days of hire and thereafter on an annual basis. This
requirement is mandated by SEC regulations and is designed to facilitate
the monitoring of personal securities transactions. Putnam's Code of
Ethics Administrator will provide Access Persons with the form for
making these reports and the specific information that must be disclosed
at the time that the disclosure is required.

Reporting Irregular Activity

Rule 4

If a Putnam employee suspects that fraudulent, illegal, or other
irregular activity (including violations of the Code of Ethics) might be
occurring at Putnam, the activity should be reported immediately to the
managing director in charge of that employee's business unit. Managing
directors who are notified of any such activity must immediately report
it in writing to Putnam's financial officer and Putnam's Chief
Compliance Officer.

An employee who does not feel comfortable reporting this activity to the
relevant managing director may instead contact the chief compliance
officer, the Putnam or MMC Ethics hotlines or the ombudsman.

Rule 5

Putnam has established a formal Office of the Ombudsman as an additional
mechanism for an employee to report an impropriety or conduct that is
not in line with the company's value system. The ombudsman is a person
who is authorized to receive complaints or questions confidentially
about alleged acts, omissions, improprieties, and broader systemic
problems within the organization. Communication with the Ombudsman is
confidential.


SECTION VI

Education Requirements

Every Putnam employee has an obligation to fully understand the
requirements of the Code of Ethics. The Rules set forth below are
designed to enhance this understanding.

Rule 1

A copy of the Code of Ethics will be distributed to every Putnam
employee periodically. All Access Persons will be required to certify
annually that they have read, understood, and will comply with the
provisions of the Code of Ethics, including the Code's Policy Statement
Concerning Insider Trading Prohibitions.

Rule 2

Every employee will annually be required to complete training on
Putnam's Code of Ethics.


SECTION VII

Compliance and Appeal Procedures

A. Assembly of Restricted List

The Code of Ethics Administrator will coordinate the assembly and
maintenance of the Restricted List. The list will be assembled each day
by 11:30 a.m. No employee may engage in a personal securities
transaction without prior clearance on any day, even if the employee
believes that the trade will be subject to an exception. Note that
pre-clearance may be obtained after 9:00 a.m. for purchases or sales of
up to 1,000 shares of issuers having a market capitalization in excess
of $5 billion.

B. Consultation of Restricted List

It is the responsibility of each employee to pre-clear through the
pre-clearance system or consult with the Code of Ethics Administrator
prior to engaging in a personal securities transaction, to determine if
the security he proposes to trade is on the Restricted List and, if so,
whether it is subject to the large-cap exception. The pre-clearance
system and the Code of Ethics Administrator will be able to tell an
employee whether a security is on the Restricted List. No other
information about the Restricted List is available through the
pre-clearance system. The Code of Ethics Administrator shall not be
authorized to answer any questions about the Restricted List, or to
render an opinion about the propriety of a particular personal
securities transaction. Any such questions shall be directed to the Code
of Ethics Officer.

C. Request for Determination

An employee who has a question concerning the applicability of the Code
of Ethics to a particular situation shall request a determination from
the Code of Ethics Officer before engaging in the conduct or personal
securities transaction about which he has a question.

If the question pertains to a personal securities transaction, the
request shall state for whose account the transaction is proposed, the
relationship of that account to the employee, the security proposed to
be traded, the proposed price and quantity, the entity with whom the
transaction will take place (if known), and any other information or
circumstances of the trade that could have a bearing on the Code of
Ethics Officer's determination. If the question pertains to other
conduct, the request for determination shall give sufficient information
about the proposed conduct to assist the Code of Ethics Officer in
ascertaining the applicability of the Code. In every instance, the Code
of Ethics Officer may request additional information, and may decline to
render a determination if the information provided is insufficient.

The Code of Ethics Officer shall make every effort to render a
determination promptly.

No perceived ambiguity in the Code of Ethics shall excuse any violation.
Any person who believes the Code to be ambiguous in a particular
situation shall request a determination from the Code of Ethics Officer.

D. Request for Ad Hoc Exemption

Any employee who wishes to obtain an ad hoc exemption under Section
I.D., Rule 2, shall request from the Code of Ethics Officer an exemption
in writing in advance of the conduct or transaction sought to be
exempted. In the case of a personal securities transaction, the request
for an ad hoc exemption shall give the same information about the
transaction required in a request for determination under number 3 of
this section, and shall state why the proposed personal securities
transaction would be unlikely to affect a highly institutional market,
or is unrelated economically to securities to be purchased, sold, or
held by any Putnam client. In the case of other conduct, the request
shall give information sufficient for the Code of Ethics Officer to
ascertain whether the conduct raises questions of propriety or conflict
of interest (real or apparent).

The Code of Ethics Officer shall make reasonable efforts to promptly
render a written determination concerning the request for an ad hoc
exemption.

E. Appeal to Code of Ethics Officer with Respect to Restricted List

If an employee ascertains that a security that he wishes to trade for
his personal account appears on the Restricted List, and thus the
transaction is prohibited, he may appeal the prohibition to the Code of
Ethics Officer by submitting a written memorandum containing the same
information as would be required in a request for a determination. The
Code of Ethics Officer shall make every effort to respond to the appeal
promptly.

F. Information Concerning Identity of Compliance Personnel

The names of Code of Ethics personnel are available by contacting the
Legal and Compliance Department and will be published on Putnam's Web
site.

APPENDIX A: Policy Statement Concerning Insider Trading Prohibitions


PREAMBLE

Putnam has always forbidden trading on material nonpublic information
(inside information) by its employees. Tough federal laws make it
important for Putnam to state that prohibition in the strongest possible
terms, and to establish, maintain, and enforce written policies and
procedures to prevent the misuse of material nonpublic information.

Unlawful trading while in possession of inside information can be a
crime. Federal law provides that an individual convicted of trading on
inside information may go to jail for a period of time. There is also
significant monetary liability for an inside trader; the Securities and
Exchange Commission can seek a court order requiring a violator to pay
back profits, as well as penalties substantially greater than those
profits. In addition private plaintiffs can seek recovery for harm
suffered by them. The inside trader is not the only one subject to
liability. In certain cases, controlling persons of inside traders
(including supervisors of inside traders or Putnam itself ) can be
liable for large penalties.

Section 1 of this Policy Statement contains rules concerning inside
information. Section 2 contains a discussion of what constitutes
unlawful insider trading.

Neither material nonpublic information nor unlawful insider trading is
easy to define. Section 2 of this Policy Statement gives a general
overview of the law in this area. However, the legal issues are complex
and must be resolved by the Code of Ethics Officer. If an employee has
any doubt as to whether she has received material nonpublic information,
she must consult with the Code of Ethics Officer prior to using that
information in connection with the purchase or sale of a security for
his own account or the account of any Putnam client, or communicating
the information to others. A simple rule of thumb is if you think the
information is not available to the public at large, don't disclose it
to others and don't trade securities to which the inside information
relates. An employee aware of or in possession of inside information
must report it immediately to the Code of Ethics Officer. If an employee
has failed to consult the Code of Ethics Officer, Putnam will not excuse
employee misuse of inside information on the ground that the employee
claims to have been confused about this Policy Statement or the nature
of the information in his possession.

If Putnam determines, in its sole discretion, that an employee has
failed to abide by this Policy Statement, or has engaged in conduct that
raises a significant question concerning insider trading, he will be
subject to disciplinary action, including termination of employment.

There are no exceptions to this policy statement and no one is exempt.

APPENDIX A

DEFINITIONS: Insider Trading

Gender references in Appendix A alternate.

Code of Ethics Administrator

The individual designated by the Code of Ethics Officer to assume
responsibility for day-to-day, non-discretionary administration of this
Policy Statement.

Code of Ethics Officer

The Putnam officer who has been assigned the responsibility of enforcing
and interpreting this Policy Statement. The Code of Ethics Officer shall
be the chief compliance officer or such other person as is designated by
the chief executive officer of Putnam Investments. If he or she is
unavailable, the Deputy Code of Ethics Officer (to be appointed by the
Code of Ethics Officer) shall act in his or her stead.

Immediate family

Spouse, minor children or other relatives living in the same household
as the Putnam employee.

Purchase or sale of a security

Any acquisition or transfer of any interest in the security for direct
or indirect consideration, including the writing of an option.

Putnam

Any or all of Putnam, LLC, and its subsidiaries, any one of which shall
be a Putnam company.

Putnam client

Any of the Putnam Funds, or any advisory or trust client of Putnam.

Putnam employee (or employee)

Any employee of Putnam.

Security

Anything defined as a security under federal law. The term includes any
type of equity or debt security, any interest in a business trust or
partnership, and any rights relating to a security, such as put and call
options, warrants, convertible securities, and securities indices.
(Note: The definition of security in this Policy Statement varies
significantly from that in the Code of Ethics. For example, the
definition in this Policy Statement specifically includes all securities
of any type.)

Transaction for a personal account (or personal securities transaction)

Securities transactions: (a) for the personal account of any employee;
(b) for the account of a member of the immediate family of any employee;
(c) for the account of a partnership in which a Putnam employee or
immediate family member is a partner with investment discretion; (d) for
the account of a trust in which a Putnam employee or immediate family
member is a trustee with investment discretion; (e) for the account of a
closely-held corporation in which a Putnam employee or immediate family
member holds shares and for which he has investment discretion; and (f )
for any account other than a Putnam client account which receives
investment advice of any sort from the employee or immediate family
member, or as to which the employee or immediate family member has
investment discretion. Officers and employees of PIL must also consult
the relevant procedures on compliance with U.K. insider dealing
legislation set forth in PIL's Compliance Manual (See Rule 3 of Section
IV of the Code of Ethics).


APPENDIX A

SECTION I: Rules Concerning Inside Information

Rule 1

No Putnam employee shall purchase or sell any security listed on the
Inside Information List (the Red List) either for his personal account
or for a Putnam client.


IMPLEMENTATION

When an employee contacts the Code of Ethics Administrator seeking
clearance for a personal securities transaction, the Code of Ethics
Administrator's response as to whether a security appears on the
Restricted List will include securities on the Red List.


COMMENT

This Rule is designed to prohibit any employee from trading a security
while Putnam may have inside information concerning that security or the
issuer. Every trade, whether for a personal account or for a Putnam
client, is subject to this Rule.

Rule 2

No Putnam employee shall purchase or sell any security, either for a
personal account or for the account of a Putnam client, while in
possession of material, nonpublic information concerning that security
or the issuer, without the prior written approval of the Code of Ethics
Officer.


IMPLEMENTATION

In order to obtain prior written approval of the Code of Ethics Officer,
a Putnam employee should follow the reporting steps prescribed in Rule 3.

COMMENTS

* Rule 1 concerns the conduct of an employee when Putnam possesses
material nonpublic information. Rule 2 concerns the conduct of an
employee who herself possesses material, nonpublic information about a
security that is not yet on the Red List.

* If an employee has any question as to whether information she
possesses is material and/or nonpublic information, she must contact the
Code of Ethics Officer in accordance with Rule 3 prior to purchasing or
selling any security related to the information or communicating the
information to others. The Code of Ethics Officer shall have the sole
authority to determine what constitutes material, nonpublic information
for the purposes of this Policy Statement.

Rule 3

Any Putnam employee who believes he may have received material,
nonpublic information concerning a security or the issuer shall
immediately report the information to the Code of Ethics Officer, the
Deputy Code of Ethics Officer or, in their absence, the general counsel
and to no one else. After reporting the information, the Putnam employee
shall comply strictly with Rule 2 by not trading in the security without
the prior written approval of the Code of Ethics Officer and shall: (a)
take precautions to ensure the continued confidentiality of the
information; and (b) refrain from communicating the information in
question to any person.


IMPLEMENTATION

A. In order to make any use of potential material, nonpublic
information, including purchasing or selling a security or communicating
the information to others, an employee must communicate that information
to the Code of Ethics Officer in a way designed to prevent the spread of
such information. Once the employee has reported potential material,
nonpublic information to the Code of Ethics Officer, the Code of Ethics
Officer will evaluate whether information constitutes material,
nonpublic information, and whether a duty exists that makes use of such
information improper. If the Code of Ethics Officer determines either
(a) that the information is not material or is public, or (b) that use
of the information is proper, he will issue a written approval to the
employee specifically authorizing trading while in possession of the
information, if the employee so requests. If the Code of Ethics Officer
determines (a) that the information may be nonpublic and material, and
(b) that use of such information may be improper, he will place the
security that is the subject of such information on the Red List.

B. An employee who reports potential inside information to the Code of
Ethics Officer should expect that the Code of Ethics Officer will need
significant information (and time to gather such information) to make
the evaluation described in the foregoing paragraph, including
information about (a) the manner in which the employee acquired the
information, and (b) the identity of individuals to whom the employee
has revealed the information, or who have otherwise learned the
information. In appropriate situations, the Code of Ethics Officer shall
place the affected security or securities on the Red List pending the
completion of his evaluation.

C. If an employee possesses documents, disks, or other materials
containing the potential inside information, an employee must take
precautions to ensure the confidentiality of the information in
question. Those precautions include (a) putting documents containing
such information out of the view of a casual observer, and (b) securing
files containing such documents or ensuring that computer files
reflecting such information are secure from viewing by others.

D. Members of the executive board of directors and members of chief
financial officer's staff may not trade securities of MMC in the period
from the end of each calendar quarter to the date of announcement of
MMC's earnings for such quarter.


COMMENTS

While all employees must pre-clear trades of MMC securities and make
sure they are not in possession of material inside information about MMC
when trading, certain employees who may receive information about
Putnam's earnings are subject to the rules above concerning trading
black out periods.


APPENDIX A

SECTION II: Overview of Insider Trading

Introduction

This section of the Policy Statement provides guidelines for employees
as to what may constitute inside information. It is possible that in the
course of her employment, an employee may receive inside information. No
employee should misuse that information, either by trading for her own
account or by communicating the information to others.

What constitutes unlawful insider trading?

The basic definition of unlawful insider trading is trading on material,
nonpublic information (also called inside information) by an individual
who has a duty not to take advantage of the information. The following
sections help explain the definition.

What is material information?

Trading on inside information is not a basis for liability unless the
information is material. Information is material if a reasonable person
would attach importance to the information in determining his course of
action with respect to a security. Information that is reasonably likely
to affect the price of a company's securities is material, but effect on
price is not the sole criterion for determining materiality. Information
that employees should consider material includes but is not limited to:
dividend changes, earnings estimates, changes in previously released
earnings estimates, reorganization, recapitalization, asset sales, plans
to commence a tender offer, merger or acquisition proposals or
agreements, major litigation, liquidity problems, significant contracts,
and extraordinary management developments.

Material information does not have to relate to a company's business.
For example, a court considered as material certain information about
the contents of a forthcoming newspaper column that was expected to
affect the market price of a security. In that case, a reporter for The
Wall Street Journal was found criminally liable for disclosing to others
the dates that reports on various companies would appear in the
Journal's "Heard on the Street" column and whether those reports would
be favorable or not.

What is nonpublic information?

Information is nonpublic until it has been effectively communicated to,
and sufficient opportunity has existed for it to be absorbed by, the
marketplace. One must be able to point to some fact to show that the
information is generally public. For example, information found in a
report filed with the Securities and Exchange Commission, or appearing
in Dow Jones, Reuters Economic Services, The Wall Street Journal, or
other publications of general circulation would be considered public.

Who has a duty not to "take advantage" of inside information?

Unlawful insider trading occurs only if there is a duty not to take
advantage of material nonpublic information. When there is no such duty,
it is permissible to trade while in possession of such information.
Questions as to whether a duty exists are complex, fact-specific, and
must be answered by a lawyer.

Insiders and Temporary Insiders

Corporate insiders have a duty not to take advantage of inside
information. The concept of insider is broad. It includes officers,
directors, and employees of a corporation. In addition, a person can be
a temporary insider if she enters into a special confidential
relationship with a corporation and as a result is given access to
information concerning the corporation's affairs. A temporary insider
can include, among others, accounting firms, consulting firms, law
firms, banks, and the employees of such organizations. Putnam would
generally be a temporary insider of a corporation it advises or for
which it performs other services, because typically Putnam clients
expect Putnam to keep any information disclosed to it confidential.


EXAMPLE

An investment advisor to the pension fund of a large publicly-traded
corporation, Acme, Inc., learns from an Acme employee that Acme will not
be making the minimum required annual contribution to the pension fund
because of a serious downturn in Acme's financial situation. The
information conveyed is material and nonpublic.


COMMENT

Neither the investment advisor or its employees, nor its clients can
trade on the basis of that information, because the investment advisor
and its employees could be considered "temporary insiders" of Acme.

Misappropriators

Certain people who are not insiders (or temporary insiders) also have a
duty not to deceptively take advantage of inside information. Included
in this category is an individual who misappropriates (or takes for his
own use) material, nonpublic information in violation of a duty owed
either to the corporation that is the subject of inside information or
some other entity. Such a misappropriator can be held liable if he
trades while in possession of that material, nonpublic information.


EXAMPLE

The Chief Investment Officer of Acme, Inc., is aware of Acme's plans to
engage in a hostile takeover of Profit, Inc. The proposed hostile
takeover is material and nonpublic.


COMMENT

The Chief Investment Officer of Acme cannot trade in Profit, Inc.'s
stock for his own account. Even though he owes no duty to Profit, Inc.,
or its shareholders, he owes a duty to Acme not to take advantage of the
information about the proposed hostile takeover by using it for his
personal benefit.

Tippers and Tippees

A person (the tippee) who receives material, nonpublic information from
an insider or misappropriator (the tipper) has a duty not to trade while
in possession of that information if he knew or should have known that
the information was provided by the tipper for an improper purpose and
in breach of a duty owed by the tipper. In this context, it is an
improper purpose for a person to provide such information for personal
benefit, such as money, affection, or friendship.


EXAMPLE

The Chief Executive Officer of Acme, Inc., tells his daughter that
negotiations concerning a previously announced acquisition of Acme have
been terminated. This news is material and, at the time the father tells
his daughter, nonpublic. The daughter sells her shares of Acme.


COMMENT

The father is a tipper because he has a duty to Acme and its
shareholders not to take advantage of the information concerning the
breakdown of negotiations, and he has conveyed the information for an
improper purpose (here, out of love and affection for his daughter). The
daughter is a tippee and is liable for trading on inside information
because she knew or should have known that her father was conveying the
information to her for his personal benefit, and that her father had a
duty not to take advantage of Acme information.

A person can be a tippee even if he did not learn the information
directly from the tipper, but learned it from a previous tippee.


EXAMPLE

An employee of a law firm which works on mergers and acquisitions learns
at work about impending acquisitions. She tells her friend and her
friend's stockbroker about the upcoming acquisitions on a regular basis.
The stockbroker tells the brother of a client on a regular basis, who in
turn tells two friends, A and B. A and B buy shares of the companies
being acquired before public announcement of the acquisition, and
regularly profit from such purchases. A and B do not know the employee
of the law firm. They do not, however, ask about the source of the
information.


COMMENT

A and B, although they have never heard of the tipper, are tippees
because they did not ask about the source of the information, even
though they were experienced investors, and were aware that the "tips"
they received from this particular source were always right.

Who can be liable for insider trading?

The categories of individuals discussed above (insiders, temporary
insiders, misappropriators, or tippees) can be liable if they trade
while in possession of material nonpublic information.

In addition, individuals other than those who actually trade on inside
information can be liable for trades of others. A tipper can be liable
if (a) he provided the information in exchange for a personal benefit in
breach of a duty, and (b) the recipient of the information (the tippee)
traded while in possession of the information.

Most importantly, a controlling person can be liable if the controlling
person knew or recklessly disregarded the fact that the controlled
person was likely to engage in misuse of inside information and failed
to take appropriate steps to prevent it. Putnam is a controlling person
of its employees. In addition, certain supervisors may be controlling
persons of those employees they supervise.


EXAMPLE

A supervisor of an analyst learns that the analyst has, over a long
period of time, secretly received material inside information from Acme,
Inc.'s Chief Investment Officer. The supervisor learns that the analyst
has engaged in a number of trades for his personal account on the basis
of the inside information. The supervisor takes no action.


COMMENT

Even if he is not liable to a private plaintiff, the supervisor can be
liable to the Securities and Exchange Commission for a civil penalty of
up to three times the amount of the analyst's profit. (Penalties are
discussed in the following section.)

Penalties for insider trading

Penalties for misuse of inside information are severe, both for
individuals involved in such unlawful conduct and their employers. A
person who violates the insider trading laws can be subject to some or
all of the types penalties below, even if he does not personally benefit
from the violation. Penalties include:

* Jail sentences, criminal monetary penalties.

* Injunctions permanently preventing an individual from working in the
securities industry.

* Injunctions ordering an individual to pay over profits obtained from
unlawful insider trading.

* Civil penalties substantially greater than the profit gained or loss
avoided by the trader, even if the individual paying the penalty did not
trade or did not benefit personally.

* Civil penalties for the employer or other controlling person.

* Damages in the amount of actual losses suffered by other participants
in the market for the security at issue.

Regardless of whether penalties or money damages are sought by others,
Putnam will take whatever action it deems appropriate (including
dismissal) if Putnam determines, in its sole discretion, that an
employee appears to have committed any violation of this Policy
Statement, or to have engaged in any conduct which raises significant
questions about whether an insider trading violation has occurred.


APPENDIX B: Policy Statement Regarding Employee Trades in Shares of
Putnam Closed-End Funds

Pre-clearance for all employees

Any purchase or sale of Putnam closed-end fund shares by a Putnam
employee must be pre-cleared by the Code of Ethics Officer or, in his
absence, the Deputy Code of Ethics Officer. A list of the closed-end
funds can be obtained from the Code of Ethics Administrator. The
automated pre-clearance system is not available for Putnam closed-end
fund clearance. Trading in shares of closed-end funds is subject to all
the rules of the Code of Ethics. Contact the Code of Ethics
Administrator with these pre-clearance requests.

Special Rules Applicable to Managing Directors of Putnam Investment
Management, LLC and officers of the Putnam Funds.

Please be aware that any employee who is a managing director of Putnam
Investment Management, Inc. (the investment manager of the Putnam mutual
funds) and officers of the Putnam Funds will not receive clearance to
engage in any combination of purchase and sale or sale and purchase of
the shares of a given closed-end fund within six months of each other.
Therefore, purchases should be made only if you intend to hold the
shares more than six months; no sales of fund shares should be made if
you intend to purchase additional shares of that same fund within six
months.

You are also required to file certain forms with the Securities and
Exchange Commission in connection with purchases and sales of Putnam
closed-end funds. Please contact the Code of Ethics Officer
Administrator for further information.

Reporting by all employees

As with any purchase or sale of a security, duplicate confirmations of
all such purchases and sales must be forwarded to the Code of Ethics
Officer by the broker-dealer utilized by an employee. If you are
required to file a quarterly report of all personal securities
transactions, this report should include all purchases and sales of
closed-end fund shares.

Please contact the Code of Ethics Officer or Deputy Code of Ethics
Officer if there are any questions regarding these matters.


APPENDIX C: Contra-Trading Rule Clearance Form

To: Code of Ethics Officer
From: __________________________________________________________________
Date: __________________________________________________________________

Re: Personal Securities Transaction of__________________________________

This serves as prior written approval of the personal securities
transaction described below:

Name of portfolio manager contemplating personal trade: ______________________

Security to be traded: _______________________________________________________

Amount to be traded: _________________________________________________________

Fund holding securities: _____________________________________________________

Amount held by fund: _________________________________________________________

Reason for personal trade: ___________________________________________________

Specific reason sale of securities is inappropriate for fund: ________________
________________________________________________________________________
________________________________________________________________________

(Please attach additional sheets if necessary.)

CIO approval: ___________________________________ Date:_______________________

Legal/compliance approval: ________________________ Date:_____________________


APPENDIX D: AIMR Code of Ethics and Standards of Professional Conduct

The Code of Ethics (Full Text)

Members of the Association for Investment Management and Research shall:

* Act with integrity, competence, dignity, and in an ethical manner when
dealing with the public, clients, prospects, employers, employees, and
fellow members.

* Practice and encourage others to practice in a professional and
ethical manner that will reflect credit on members and their profession.

* Strive to maintain and improve their competence and the competence of
others in the profession.

* Use reasonable care and exercise independent professional judgment.

The Standards of Professional Conduct

All members of the Association for Investment Management and Research
and the holders of and candidates for the Chartered Financial Analyst
designation are obligated to conduct their activities in accordance with
the following Code of Ethics. Disciplinary sanctions may be imposed for
violations of the Code and Standards.

* Fundamental responsibilities
* Relationships with and responsibilities to a profession
* Relationships with and responsibilities to an employer
* Relationships with and responsibilities to clients and prospects
* Relationships with and responsibilities to the public
* Standards of Practice Handbook

Fundamental Responsibilities

Members shall maintain knowledge of and comply with all applicable laws,
rules, and regulations (including AIMR's Code of Ethics and Standards of
Professional Conduct) of any government, governmental agency, regulatory
organization, licensing agency, or professional association governing
the members' professional activities. Not knowingly participate in or
assist any violation of such laws, rules, or regulations.

Relationships with and Responsibilities to the Profession

Use of Professional Designation

AIMR members may reference their membership only in a dignified and
judicious manner. The use of the reference may be accompanied by an
accurate explanation of the requirements that have been met to obtain
membership in these organizations.

Those who have earned the right to use the Chartered Financial Analyst
designation may use the marks "Chartered Financial Analyst" or "CFA" and
are encouraged to do so, but only in a proper, dignified, and judicious
manner. The use of the designation may be accompanied by an accurate
explanation of the requirements that have been met to obtain the right
to use the designation.

Candidates in the CFA Program, as defined in the AIMR Bylaws, may
reference their participation in the CFA Program, but the reference must
clearly state that an individual is a candidate in the CFA Program and
cannot imply that the candidate has achieved any type of partial
designation.

Professional Misconduct

Members shall not engage in any professional conduct involving
dishonesty, fraud, deceit, or misrepresentation or commit any act that
reflects adversely on their honesty, trustworthiness, or professional
competence.

Members and candidates shall not engage in any conduct or commit any act
that compromises the integrity of the CFA designation or the integrity
or validity of the examinations leading to the award of the right to use
the CFA designation.

Prohibition against Plagiarism

Members shall not copy or use, in substantially the same form as the
original, material prepared by another without acknowledging and
identifying the name of the author, publisher, or source of such
material. Members may use, without acknowledgment, factual information
published by recognized financial and statistical reporting services or
similar sources.

Relationships with and Responsibilities to the Employer

Obligation to Inform Employer of Code and Standards

Members shall inform their employer in writing, through their direct
supervisor, that they are obligated to comply with the Code and
Standards and are subject to disciplinary sanctions for violations
thereof.

Members shall deliver a copy of the Code and Standards to their employer
if the employer does not have a copy.

Duty to Employer

Members shall not undertake any independent practice that could result
in compensation or other benefit in competition with their employer
unless they obtain written consent from both their employer and the
persons or entities for whom they undertake independent practice.

Disclosure of Conflicts to Employer

Members shall comply with any prohibitions on activities imposed by
their employer if a conflict of interest exists.

Disclosure of Additional Compensation Arrangements

Members shall disclose to their employer in writing all monetary
compensation or other benefits that they receive for their services that
are in addition to compensation or benefits conferred by a member's
employer.

Responsibilities of Supervisors

Members with supervisory responsibility, authority, or the ability to
influence the conduct of others shall exercise reasonable supervision
over those subject to their supervision or authority to prevent any
violation of applicable statutes, regulations, or provisions of the Code
and Standards. In so doing, members are entitled to rely on reasonable
procedures to detect and prevent such violations.

Relationships with and Responsibilities to Clients and Prospects

Investment Process

REASONABLE BASIS AND REPRESENTATIONS

* Exercise diligence and thoroughness in making investment
recommendations or in taking investment actions.

* Have a reasonable and adequate basis, supported by appropriate
research and investigation, for such recommendations or actions.

* Make reasonable and diligent efforts to avoid any material
misrepresentation in any research report or investment recommendation.

* Maintain appropriate records to support the reasonableness of such
recommendations or actions.


RESEARCH REPORTS


* Use reasonable judgment regarding the inclusion or exclusion of
relevant factors in research reports.

* Distinguish between facts and opinions in research reports.

* Indicate the basic characteristics of the investment involved when
preparing for public distribution a research report that is not directly
related to a specific portfolio or client.


INDEPENDENCE AND OBJECTIVITY

* Members shall use reasonable care and judgment to achieve and maintain
independence and objectivity in making investment recommendations or
taking investment action.

Interactions with Clients and Prospects

FIDUCIARY DUTIES

In relationships with clients, members shall use particular care in
determining applicable fiduciary duty and shall comply with such duty as
to those persons and interests to whom the duty is owed. Members must
act for the benefit of their clients and place their clients' interests
before their own.


PORTFOLIO INVESTMENT RECOMMENDATIONS AND ACTIONS

Members shall:

* Make a reasonable inquiry into a client's financial situation,
investment experience, and investment objectives prior to making any
investment recommendations and shall update this information as
necessary, but no less frequently than annually, to allow the members to
adjust their investment recommendations to reflect changed
circumstances.

* Consider the appropriateness and suitability of investment
recommendations or actions for each portfolio or client. In determining
appropriateness and suitability, members shall consider applicable
relevant factors, including the needs and circumstances of the portfolio
or client, the basic characteristics of the investment involved, and the
basic characteristics of the total portfolio.

* Members shall not make a recommendation unless they reasonably
determine that the recommendation is suitable to the client's financial
situation, investment experience, and investment objectives.

* Distinguish between facts and opinions in the presentation of
investment recommendations.

* Disclose to clients and prospects the basic format and general
principles of the investment processes by which securities are selected
and portfolios are constructed and shall promptly disclose to clients
and prospects any changes that might significantly affect those
processes.

FAIR DEALING

Members shall deal fairly and objectively with all clients and prospects
when disseminating investment recommendations, disseminating material
changes in prior investment recommendations, and taking investment
action.


PRIORITY OF TRANSACTIONS

Transactions for clients and employers shall have priority over
transactions in securities or other investments of which a member is the
beneficial owner so that such personal transactions do not operate
adversely to their clients' or employer's interests. If members make a
recommendation regarding the purchase or sale of a security or other
investment, they shall give their clients and employer adequate
opportunity to act on their recommendations before acting on their own
behalf. For purposes of the Code and Standards, a member is a
"beneficial owner" if the member has:

* direct or indirect pecuniary interest in the securities;

* the power to vote or direct the voting of the shares of the securities
or investments;

* the power to dispose or direct the disposition of the security or
investment.


PRESERVATION OF CONFIDENTIALITY

Members shall preserve the confidentiality of information communicated
by clients, prospects, or employers concerning matters within the scope
of the client-member, prospect-member, or employer-member relationship
unless a member receives information concerning illegal activities on
the part of the client, prospect, or employer.


PROHIBITION AGAINST MISREPRESENTATION


Members shall not make any statements, orally or in writing, that
misrepresent

* the services that they or their firms are capable of performing;

* their qualifications or the qualifications of their firm;

* the member's academic or professional credentials.

Members shall not make or imply, orally or in writing, any assurances or
guarantees regarding any investment except to communicate accurate
information regarding the terms of the investment instrument and the
issuer's obligations under the instrument.


DISCLOSURE OF CONFLICTS TO CLIENTS AND PROSPECTS

Members shall disclose to their clients and prospects all matters,
including beneficial ownership of securities or other investments, that
reasonably could be expected to impair the members' ability to make
unbiased and objective recommendations.


DISCLOSURE OF REFERRAL FEES

Members shall disclose to clients and prospects any consideration or
benefit received by the member or delivered to others for the
recommendation of any services to the client or prospect.

Relationships with and Responsibilities to the Public

PROHIBITION AGAINST USE OF MATERIAL NONPUBLIC INFORMATION

Members who possess material nonpublic information related to the value
of a security shall not trade or cause others to trade in that security
if such trading would breach a duty or if the information was
misappropriated or relates to a tender offer. If members receive
material nonpublic information in confidence, they shall not breach that
confidence by trading or causing others to trade in securities to which
such information relates. Members shall make reasonable efforts to
achieve public dissemination of material nonpublic information disclosed
in breach of a duty.


PERFORMANCE PRESENTATION

Members shall not make any statements, orally or in writing, that
misrepresent the investment performance that they or their firms have
accomplished or can reasonably be expected to achieve. If members
communicate individual or firm performance information directly or
indirectly to clients or prospective clients, or in a manner intended to
be received by clients or prospective clients, members shall make every
reasonable effort to assure that such performance information is a fair,
accurate, and complete presentation of such performance.

APPENDIX E: Report of Entertainment Form


This form must be filed with the Putnam Legal and Compliance Department
within 10 days of date of entertainment.

Send to:
Laura Rose
Assistant Vice President and Code of Ethics Administrator
Mailstop L-5

OR

Attach to an e-mail to:
laura_rose@putnam.com

Name of employee:____________________________________________

Name of party providing entertainment:

Firm: _______________________________________________________

Person:______________________________________________________

Date of entertainment:_______________________________________

Describe entertainment provided:_____________________________
(e.g., name and location of restaurant, sporting, or cultural event)

Value of entertainment (excluding meals):____________________

Signature: ____________________________________ Date:_______________


INDEX

7-Day Rule
transactions by portfolio managers,
analysts, and CIOs .......................................................14
60-Day Rule...............................................................13

A

Access Persons
definition ............................................................. vii
special rules on trading..................................................13
AIMR Code of Ethics and Standards of
Professional Conduct .................................................... 47
Analysts
special rules on trading................................................. 14
Appeals
Procedures................................................................36

B

Bankers' acceptances
excluded from securities ...............................................viii
Blackout rule
trading by portfolio managers,
analysts and CIOs........................................................ 15
Boycott
anti-trust and other laws.................................................18
Bribes ...................................................................21

C

Certificates of Deposit
excluded from securities ...............................................viii
Clearance
how long pre-clearance is valid............................................2
required for personal
securities transactions ...................................................1
Closed-end funds
pre-clearance and reporting ..............................................45
Commercial paper
excluded from securities ...............................................viii
Commodities (other than securities indices)
excluded from securities ...............................................viii
Computer use
compliance with corporate
policies required ........................................................26
Confidentiality
required of all employees.............................................22, 26
Confirmations and broker statements
required for personal transactions........................................31
Conflicts of interest
with Putnam and Putnam clients............................................18
Contra-trading rule
transactions by portfolio managers
and CIOs .................................................................16
Convertible securities
defined as securities...................................................viii
Currencies
excluded as securities..................................................viii

D

Definitions..............................................................vii
Director
prohibited to serve for another entity....................................23
Dividend reinvestment program.............................................11

E

Employee
prohibited to serve for another entity ...................................23
Excessive trading (over 25 trades) prohibited ............................10
Exchange traded index funds,
excluded from securities ...............................................viii
Exemptions..........................................................3, 4, 11

F

Family members
covered in personal
securities transactions .........................................viii, 7, 38
Fiduciary
prohibited to serve for another entity....................................23
Fraudulent or irregular activities
reporting ................................................................24

G

Gifts and Entertainment Policy .......................................18, 19
Good-until-canceled orders................................................10

H

Holdings of securities
disclosure by Access Persons..............................................32

I

Initial public offerings/IPOs
purchases are prohibited...................................................5
Insider trading
policy statement and explanations ........................................38
prohibited............................................................iii, 5
Investment clubs
prohibited................................................................23
Involuntary personal securities transactions
exemptions ............................................................4, 11

L

Large Cap Exception
for clearance of securities on
Restricted List............................................................2
Limit Orders..............................................................10

M

Market timing prohibition..................................................9
Money market instruments
excluded from securities............................................... viii

N

Naked options
by employees discouraged..................................................11
Non-Putnam affiliates (NPAs)
transactions and relationships............................................25

O

Officer
prohibited to serve for another entity ...............................22, 23
Options
defined as securities...................................................viii
relationship to securities on
Restricted or Red Lists....................................................3
Ombudsman.................................................................33

P

Partner
prohibited to serve as general partner of
another entity........................................................... 23
Partnerships
covered in personal securities
transactions ...................................................... viii, 37
Personal securities transaction
defined ............................................................viii, 38
Political contributions...................................................21
Portfolio managers
special rules on trading..............................................14, 17
Privacy policy ...........................................................26
Private offerings, purchases in private
placements................................................................ 6
Putnam Investments Limited
special rules ............................................................29

Q

Quarterly Report of securities transactions ..............................32

R

Reporting requirements....................................................31
Repurchase agreements
excluded from securities................................................viii

S

Sanctions ................................................................vi
for failure to pre-clear properly ........................................ 4
Shares by subscription
procedures to preclear trades............................................. 2
Short sales
prohibited conduct........................................................ 5

T

Tender offers .............................................................4
Trustee
prohibited to serve for another entity....................................23
Trusts
covered in personal securities
transactions .......................................................viii, 38

U

U.S. government obligations
excluded from securities................................................viii

V

Violations of Law
reporting ................................................................33

W

Warrants
defined as securities...................................................viii

PUTNAM INVESTMENTS

One Post Office Square
Boston, Massachusetts 02109
1-800-225-1581
www.putnaminvestments.com                                        215845 8/04

EX-99.P CODE ETH

Supplement - dated December 15, 2004 to Putnam Code of Ethics

The Putnam Code of Ethics Oversight Committee has approved the following
amendments to the August 2004 Code of Ethics.

Sanctions Guidelines

The Sanctions Guidelines in Section 1A of the Code (page 4 of August
Code) have been withdrawn and are replaced with the following new
Sanctions Guidelines effective with the first quarter of  2005:

"The Code of Ethics Oversight Committee is responsible for setting
sanctions policies for violating the Code. The Committee has adopted the
following minimum monetary sanctions for violations of the Code.  These
sanctions apply even if the exception results from inadvertence rather
than intentional misbehavior.  The Code of Ethics Officer is authorized
to impose the minimum sanction on employees without further Committee
action.  However, the sanctions noted below are only minimums and the
Committee reserves the right to impose additional sanctions such as
higher monetary sanctions, trading bans, suspension or termination of
employment as it determines to be  appropriate.

The minimum sanction for a violation of the following Rules is
disgorgement of any profits or payment of avoided losses and the
following payments:

Section IA, Rule 1 (Pre-clearance and Restricted List)
Section IB, Rule 1 (Short-selling)
Section IB, Rule 2 (IPOs)
Section IB, Rule 3 (Private Placements)
Section IB, Rule 4 (Trading with Inside Information)
Section IB, Rules 6-8 (Holding and trading of Putnam Funds)
Section II, Rule 2 (7-Day Rule)
Section II, Rule 3 (Black-out Rule)
Section II, Rule 4, (Contra-Trading Rule)
Section II, Rule 5 (Trading for personal benefit)


Officer Level    SMD/MD         SVP/VP         AVP/non-officer
- --------------------------------------------------------------------------
1st violation     $500           $250           $50
2nd             $1,000           $500          $100
3rd             Minimum monetary sanction as above with ban on all new
                personal individual investments.

The minimum sanction for violations of all other rules in the Code is as
follows:

Officer Level    SMD/MD         SVP/VP         AVP/non-officer
- --------------------------------------------------------------------------
1st violation     $100            $50           $25
Subsequent        $200           $100           $50

The reference period for determining whether a violation is initial or
subsequent will be five years.

Excessive Trading

Effective with the 2nd quarter of 2005, the maximum number of trades
permitted in individual securities per quarter is reduced from 25 to 10.
Section 1B, Rule 9 is effective April 1, 2005, will read as follows:

"Putnam employees are strongly discouraged from engaging in excessive
trading for their personal accounts.  Beginning in the second quarter of
2005, employees will be prohibited from making more than 10 trades in
individual securities in any given quarter.  Excessive trading within
Putnam open-end funds is prohibited."

Access Persons; Holding Period for Individual Securities

Effective with the 2nd quarter of 2005, the holding period rule for
Access Person investments in individual securities will increase from 60
to 90 days.  Section II, Rule 1 will read, effective April 1, 2005 as
follows:

"No Access Person shall purchase and then sell at a profit, or sell and
then repurchase at a lower price, any security or related derivative
security with 90 calendar days."

Access Person Reporting

The deadline by which Access Persons are required to file quarterly
statements of all transactions has been increased from 10 to 15 calendar
days after the end of each quarter.  This change will be effective in
the April, 2005 filing.  Accordingly Section V, Rule 2, will now read as
follows:

"Every Access Person shall file a quarterly report within 15 calendar
days of the end of each quarter, recording all purchases and sales of
any securities for personal accounts as defined in the Definitions. (For
purposes of this Rule, securities shall include exchange traded funds
(ETFs), futures and any option on a security or securities index,
including broad based market indices excluded from the pre-clearance
requirement and also includes transactions in Putnam open-end funds if
the account for the Putnam funds is not held at Putnam Securities
Services or in a Putnam retirement plan and for transactions in US
mutual funds sub-advised by Putnam."

Access Person Definition

As required by new SEC rule 204A-1, the definition of Access Persons
under the Code has been amended, effective February 1, 2005 to include
Putnam employees with access to non public information about affiliated
mutual fund portfolio holdings.  The definition of Access Person will
read as of February 1, 2005 as follows:

"Access Persons are:

(a) all employees in Putnam's Investment Division;

(b) all directors and officers of all Putnam entities which are SEC
    registered investment advisers;

(c) all members of Putnam's Executive Board and all Managing Directors
    in Putnam's marketing and sales organizations; and

(d) any other employee of Putnam who, in connection with regular duties,
    has access to nonpublic information about any client's purchase or sale
    of securities or to information regarding recommendations with respect
    to such purchases or sales or who has access to nonpublic information
    regarding the portfolio holdings of any Putnam advised or sub-advised
    mutual fund.

Each employee will be informed if he or she is considered an Access
Person.  The Code of Ethics Officer maintains a list of all Access
Persons."

EX-99.P CODE ETH

                             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 and Reporting.

(1) The Code of Ethics Officer shall cause the reported personal
securities transactions to be compared 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 any
provision of this Code has or may have occurred, he shall submit his
written determination, together with any additional explanatory
material, to the Audit and Pricing Committee of the Funds at its next
meeting.

D. Sanctions.  In addition to reporting violations of this Code to the
Audit and Pricing Committee of the Funds as provided in Section I-C(2),
the Code of Ethics officer shall also report to such Committee any
sanctions imposed with respect to such violations.  The Committee
reserves the right to impose such additional sanctions as it deems
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 high-quality short-term
debt investments, including repurchase agreements, and shares of
registered open-end investment companies, but shall include any security
convertible into or exchangeable for a security.

(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 of securities effected in any account over which
the Unaffiliated Trustee has no direct or indirect influence or control;

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

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

(4) purchases of securities 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 of securities 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 Legal and Compliance Liaison Officer of the
Funds, in consultation with the Code of Ethics Officer, which approval
shall be confirmed in writing.

D. Reporting.

(1) Whether or not one of the exemptions listed in Section II-C applies
and except as provided in Section II-C(5), every Unaffiliated Trustee of
a Fund shall file with the Funds' Legal and Compliance Liaison Officer a
report containing the information described in Section II-D(2) of this
Code with respect to purchases or sales of 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, the number of shares, the
interest rate and maturity date (if applicable) 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; and

(e) the date that the report is submitted by each Unaffiliated Trustee.

(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 Funds shall
file the reports required by Rule 17j-1(d)(1) under the Investment
Company Act of 1940 with the Code of Ethics Officer of Putnam
Investments.  Such reports shall be reviewed by such Officer as provided
in Section I-C(1) and any related violations shall be reported by him to
the Audit and Pricing Committee as provided in Section I-C(2).  The
Committee may impose such additional sanctions as it deems appropriate.

E. Review and Reporting.

(1) The Legal and Compliance Liaison Officer of the Funds, in
consultation with the Code of Ethics Officer of Putnam Investments,
shall cause the reported personal securities transactions that he
receives pursuant to Section II-D(1) to be compared 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 Legal and Compliance Liaison Officer 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 Legal and Compliance
Liaison Officer shall give the person involved an opportunity to supply
additional information regarding the transaction in question.

F. Sanctions.  If the Legal and Compliance Liaison determines that a
violation of this Code has occurred, he shall so advise the Funds' Audit
and Pricing Committee, and 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
November 1, 2004

EX-99.P CODE ETH

Supplement - dated April 1, 2005 to Putnam's Code of Ethics

The Putnam Code of Ethics Oversight Committee has approved the following
amendments, effective April 1, 2005:

Section III - Rule 12: Interest in Entities Doing Business with Putnam

Family Member Conflicts Policy

No employee or member of an employee's immediate family shall have any
direct or indirect personal financial interests in companies which do
business with Putnam, unless such interest is disclosed and approved by
the Code of Ethics Officer. Investment holdings in public companies
which are not material to the employee are excluded from this
prohibition. The Code also provides more detailed supplemental rules to
address potential conflicts of interests which may arise if members of
employees' families are closely involved in doing business with Putnam.

Corporate purchase of goods and services

Putnam will not acquire goods and services from any firm in which a
member of an employee's immediate family serves as the sales
representative in a senior management capacity or has an ownership
interest with the supplier firm (excluding normal investment holdings in
public companies) without permission from the Director of Procurement
and the Code of Ethics Officer. Any employee who is aware of a proposal
to purchase goods and services from a firm at which a member of the
employee's immediate family meets one of the previously mentioned
conditions must notify the Director of Procurement and the Code of
Ethics Officer.

Portfolio Trading

Putnam will not allocate any trades for a portfolio to any firm that
employs a member of an employee's immediate family as a sales
representative to Putnam (in a primary, secondary or back up role). Any
Putnam employee who is aware that an immediate family member serves as a
broker-dealer's sales representative to Putnam should inform the Code of
Ethics Officer.

Definition of Immediate Family

"Immediate family" of an employee means (1) husband or wife of the
employee, (2) any child, sibling or parent of an employee and any person
married to a child, sibling, or parent of an employee and (3) any other
person who lives in the same household as the employee.

Section III - Rule 5: Political Contributions/Solicitations Policy

Political Activities, Contributions and Lobbying

Corporate Contributions and Solicitation.  Political activities of
corporations such as Putnam are highly regulated, and corporate
political contributions are largely prohibited.  Accordingly, no
contributions may be made with Putnam corporate funds to any political
party or campaign, whether directly or by reimbursement of such a
contribution, unless pre-approved in advance by the Chief Compliance
Officer.  Employee contributions to any pending or proposed client of
Putnam, regardless of whether the employee will seek reimbursement from
Putnam for such contributions, must be pre-approved in advance by the
Chief Compliance Officer. Donations of Putnam property and of employee
time when working for Putnam are also prohibited. No Putnam employee may
make any solicitation for or endorsement of any campaign or candidate
using Putnam letterhead, referencing Putnam, or while on Putnam
business.

Employee Personal Political Contributions. Employees, so long as they do
not use Putnam assets, or state or imply that Putnam is involved in a
campaign, are free to engage in political activities subject to three
restrictions as follows:

1. Some states and localities have laws that prohibit employees from
making political contributions to candidates for state and local office
if their employer has an investment management contract with, or is
seeking one from, the state or locality. Accordingly, Putnam employees
must pre-clear with the Chief Compliance Officer any contributions to
candidates for any of the following offices:

* State or local offices in California
* The office of State Treasurer of Connecticut or Vermont
* State or local offices in New Jersey
* Any local office in the city of Houston, Texas

2. Contributions to state and local officials with whom Putnam has a
business relationship or from whom is seeking a business relationship
must be pre-cleared with the Chief Compliance Officer.

3. Certain employees at PRM involved in the CollegeAdvantage program are
restricted from making contributions to candidates for offices in Ohio
under the rules of the Municipal Securities Rulemaking Board. These
employees are separately identified and informed by Putnam's Compliance
Department of applicable requirements.

Gifts. Employees must obtain pre-approval from the Chief Compliance
Officer prior to providing any gift (including meals, entertainment,
transportation or lodging) to any government official or employee.

Lobbying.  Federal and state law imposes limits and registration
requirements on efforts by individuals and companies to influence the
passage of legislation or to obtain business from governments.
Accordingly, Putnam employees should not engage in any lobbying
activities without approval from Putnam's Director of Government
Relations. Lobbying does not include solicitation of investment
management business through the ordinary course of business, such as
responding to RFPs.