CODE OF ETHICS

FOR

SENIOR OFFICERS

Policy

This Code of Ethics for Senior Officers (this “Code”) sets forth the policies, practices and values expected to be exhibited by Senior Officers of the Pioneer Funds (collectively, the “Funds” and each, a “Fund”). This Code does not apply generally to officers and employees of service providers to the Funds, including Amundi Asset Management US, Inc., and Amundi Distributor US, Inc. (collectively, “Amundi US”), unless such officers and employees are also Senior Officers.

The term “Senior Officers” shall mean the principal executive officer, principal financial officer, principal accounting officer and controller of the Funds, although one person may occupy more than one such office. Each Senior Officer is identified by title in Exhibit A to this Code.

The Chief Compliance Officer (“CCO”) of the Pioneer Funds is primarily responsible for implementing and monitoring compliance with this Code, subject to the overall supervision of the Board of Trustees of the Funds (the “Board”). The CCO has the authority to interpret this Code and its applicability to particular situations. Any questions about this Code should be directed to the CCO or his or her designee.

Purpose

The purposes of this Code are to:

Promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

Promote full, fair, accurate, timely and understandable disclosure in reports and documents that the Fund files with, or submits to, the Securities and Exchange Commission (“SEC”) and in other public communications made by the Fund;


	1	Last revised January 2021

Promote compliance with applicable laws and governmental rules and regulations;

Promote the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

Establish accountability for adherence to the Code.

Each Senior Officer should adhere to a high standard of business ethics and should be sensitive to situations that may give rise to actual as well as apparent conflicts of interest.

Responsibilities of Senior Officers

Conflicts of Interest

A “conflict of interest” occurs when a Senior Officer’s private interests interfere in any way – or even appear to interfere – with the interests of or his/her service to a Fund. A conflict can arise when a Senior Officer takes actions or has interests that may make it difficult to perform his or her Fund work objectively and effectively. Conflicts of interest also arise when a Senior Officer or a member of his/her family receives improper personal benefits as a result of the Senior Officer’s position with the Fund.

Certain conflicts of interest arise out of the relationships between Senior Officers and the Fund and already are subject to conflict of interest provisions in the Investment Company Act of 1940, as amended (the “ICA”), and the Investment Advisers Act of 1940, as amended (the “IAA”). For example, Senior Officers may not individually engage in certain transactions (such as the purchase or sale of securities or other property) with the Funds because of their status as “affiliated persons” of the Funds. The Fund's and Amundi US’ compliance programs and procedures are designed to prevent, or identify and correct, violations of these provisions. This Code does not, and is not intended to, repeat or replace such policies and procedures, and such conflicts fall outside of the parameters of this Code.

Although typically not presenting an opportunity for improper personal benefit, conflicts arise as a result of the contractual relationship between the Fund and Amundi US because the Senior Officers are officers or employees of both. As a result, this Code recognizes that Senior Officers will, in the normal course of their duties (whether formally for a Fund or for Amundi US, or for both), be involved in establishing policies and implementing decisions that will have different effects on Amundi US and the Fund. The participation of Senior Officers in such activities is inherent in the contractual relationship between a Fund and Amundi US and is consistent with the performance by the Senior Officers of their duties as officers of the Fund and, if addressed in conformity with the provisions of the ICA and the IAA, will be deemed to have been handled ethically. In addition, it is recognized by the Board that Senior Officers may also be officers of investment companies other than the Pioneer Funds.

Other conflicts of interest are covered by this Code, even if such conflicts of interest are not subject to provisions of the ICA or the IAA. In reading the following examples of conflicts of interest under this Code, Senior Officers should keep in mind that such a list cannot ever be exhaustive or cover every possible scenario. It follows that the overarching principle is that the personal interest of a Senior Officer should not be placed improperly before the interest of a Fund.


	2	Last revised January 2021

Each Senior Officer must:

Not use his or her personal influence or personal relationships improperly to influence investment decisions or financial reporting by a Fund whereby the Senior Officer would benefit personally to the detriment of the Fund;

Not cause a Fund to take action, or fail to take action, for the individual personal benefit of the Senior Officer rather than the benefit of the Fund; and

Report at least annually any affiliations or other relationships that give rise to conflicts of interest.

Any material conflict of interest situation should be approved by the CCO, his or her designee or the Board. Examples of these include:

Service as a director on the board of any public or private company;

The receipt of any gift with a value in excess of an amount established from time to time by Amundi US’ Business Gift and Entertainment Policy from any single non-relative person or entity. Customary business lunches, dinners and entertainment at which both the Senior Officer and the giver are present, and promotional items of insignificant value are exempt from this prohibition;

The receipt of any entertainment from any company with which a Fund has current or prospective business dealings unless such entertainment is business-related, reasonable in cost, appropriate as to time and place, and not so frequent as to raise any question of impropriety;

Any ownership interest in, or any consulting or employment relationship with, any of a Fund’s service providers other than its investment adviser, principal underwriter, administrator or any affiliated person thereof; and

A direct or indirect financial interest in commissions, transaction charges or spreads paid by a Fund for effecting portfolio transactions or for selling or redeeming shares other than an interest arising from the Senior Officer’s employment, such as compensation or equity ownership.

Corporate Opportunities

Senior Officers may not (a) take for themselves personally opportunities that are discovered through the use of a Fund’s property, information or position; (b) use a Fund’s property, information, or position for personal gain; or (c) compete with a Fund. Senior Officers owe a duty to the Funds to advance their legitimate interests when the opportunity to do so arises.


	3	Last revised January 2021

Confidentiality

Senior Officers should maintain the confidentiality of information entrusted to them by the Funds, except when disclosure is authorized or legally mandated. Confidential information includes all non-public information that might be of use to competitors, or harmful to the Funds, if disclosed.

Fair dealing with Fund shareholders, suppliers, and competitors

Senior Officers should endeavor to deal fairly with the Funds’ shareholders, suppliers, and competitors. Senior Officers should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Senior Officers should not knowingly misrepresent or cause others to misrepresent facts about a Fund to others, whether within or outside the Fund, including to the Board, the Funds’ auditors or to governmental regulators and self-regulatory organizations.

Compliance with Law

Each Senior Officer must not knowingly violate any law, rule and regulation applicable to his or her activities as an officer of the Funds. In addition, Senior Officers are responsible for understanding and promoting compliance with the laws, rules and regulations applicable to his or her particular position and by persons under the Senior Officer’s supervision. Senior Officers should endeavor to comply not only with the letter of the law, but also with the spirit of the law.

Disclosure

Each Senior Officer should familiarize himself or herself with the disclosure requirements generally applicable to the Funds. Each Senior Officer should, to the extent appropriate within his or her area of responsibility, consult with other officers of the Funds and Amundi US with the goal of promoting full, fair, accurate, timely and understandable disclosure in the reports and documents a Fund files with, or submits to, the SEC and in other public communications made by the Funds.

Initial and Annual Certifications

Upon becoming a Senior Officer the Senior Officer is required to certify that he or she has received, read, and understands this Code. On an annual basis, each Senior Officer must certify that he or she has complied with all of the applicable requirements of this Code.

Administration and Enforcement of the Code

Report of Violations

Amundi US relies on each Senior Officer to report promptly if he or she knows of any conduct by a Senior Officer in violation of this Code. All violations or suspected violations of this Code must be reported to the CCO or a member of Amundi US’ Legal and Compliance Department. Failure to do so is itself a violation of this Code.


	4	Last revised January 2021

Investigation of Violations

Upon notification of a violation or suspected violation, the CCO or other members of Amundi US’ Compliance Department will take all appropriate action to investigate the potential violation reported. If, after such investigation, the CCO believes that no violation has occurred, the CCO and Compliance Department is not required to take no further action. Any matter the CCO believes is a violation will be reported to the Independent Trustees. If the Independent Trustees concur that a violation has occurred, they will inform and make a recommendation to the full Board. The Board shall be responsible for determining appropriate action. The Funds, their officers and employees, will not retaliate against any Senior Officer for reports of potential violations that are made in good faith and without malicious intent.

The CCO or his or her designee is responsible for applying this Code to specific situations in which questions are presented under it and has the authority to interpret this Code in any particular situation. The CCO or his or her designee shall make inquiries regarding any potential conflict of interest.

Violations and Sanctions

Compliance with this Code is expected and violations of its provisions will be taken seriously and could result in disciplinary action. In response to violations of the Code, the Board may impose such sanctions as it deems appropriate within the scope of its authority over Senior Officers, including termination as an officer of the Funds.

Waivers from the Code

The Independent Trustees will consider any approval or waiver sought by any Senior Officer.

The Independent Trustees will be responsible for granting waivers, as appropriate. Any change to or waiver of this Code will, to the extent required, be disclosed as provided by SEC rules.

Other Policies and Procedures

This Code shall be the sole Code of Ethics adopted by the Funds for purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to registered investment companies thereunder. The Funds’ and Amundi US’ Codes of Ethics under Rule 17j-1 under the ICA and Rule 204A-1 of the IAA are separate requirements applying to the Senior Officers and others, and are not a part of this Code. To the extent any other policies and procedures of the Funds or Amundi US overlap or conflict with the provisions of the Code, they are superseded by this Code.

Scope of Responsibilities

A Senior Officer’s responsibilities under this Code are limited to Fund matters over which the Senior Officer has direct responsibility or control, matters in which the Senior Officer routinely participates, and matters with which the Senior Officer is otherwise involved. In addition, a Senior Officer is responsible for matters of which the Senior Officer has actual knowledge.


	5	Last revised January 2021

Amendments

This Code other than Exhibit A may not be amended except in a writing that is specifically approved or ratified by a majority vote of the Board, including a majority of the Independent Trustees.

Confidentiality

All reports and records prepared or maintained pursuant to this Code will be considered confidential and shall be maintained and protected accordingly. Except as otherwise required by law or this Code, such matters shall not be disclosed to anyone other than the Board and their counsel, or to Amundi US’ Legal and Compliance Department.

Internal Use

This Code is intended solely for the internal use by the Funds and does not constitute an admission, by or on behalf of any Fund, as to any fact, circumstance, or legal conclusion.


	6	Last revised January 2021

Exhibit A – Senior Officers of the Pioneer Funds (Effective as of August 14, 2008)

President (Principal Executive Officer)

Treasurer (Principal Financial Officer)

Code of Ethics for Senior Officers

Table of Contents
President’s Letter	2
Portfolio Management Discussion	4
Portfolio Summary	10
Prices and Distributions	11
Performance Update	12
Comparing Ongoing Fund Expenses	15
Schedule of Investments	17
Financial Statements	20
Notes to Financial Statements	27
Report of Independent Registered Public Accounting Firm	37
Additional Information	39
Approval of Renewal of Investment Management Agreement	40
Trustees, Officers and Service Providers	45

10 Largest Holdings
(As a percentage of total investments)*
1.	Prologis, Inc.	9.84%
2.	Equinix, Inc.	7.61
3.	Simon Property Group, Inc.	6.19
4.	National Storage Affiliates Trust	4.94
5.	EastGroup Properties, Inc.	4.92
6.	Innovative Industrial Properties, Inc.	4.83
7.	Extra Space Storage, Inc.	4.76
8.	DigitalRealty Trust, Inc.	4.52
9.	Mid-America Apartment Communities, Inc.	3.84
10.	Sun Communities, Inc.	3.24

Class	12/31/21	12/31/20
A	$17.77	$13.13
C	$16.93	$12.55
Y	$17.71	$13.09

	Net Investment	Short-Term	Long-Term
Class	Income	Capital Gains	Capital Gains
A	$0.1439	$ —	$0.5215
C	$0.0200	$ —	$0.5215
Y	$0.1868	$ —	$0.5215

Average Annual Total Returns
(As of December 31, 2021)
	Net	Public	MSCI
	Asset	Offering	U.S.
	Value	Price	REIT
Period	(NAV)	(POP)	Index
10 years	10.39%	9.74%	11.32%
5 years	9.88	8.59	10.78
1 year	40.91	32.82	43.06

Expense Ratio
(Per prospectus dated May 1, 2021)
Gross	Net
1.65%	1.50%

Share Class	A	C	Y
Beginning Account	$1,000.00	$1,000.00	$1,000.00
Value on 7/1/21
Ending Account	$1,201.07	$1,194.96	$1,202.71
Value on 12/31/21
Expenses Paid	$8.32	$13.61	$6.66
During Period*

Shares			Value
		UNAFFILIATED ISSUERS — 99.9%
		COMMON STOCKS — 99.4% of Net Assets
		Equity Real Estate Investment Trusts (REITs) — 96.2%
	12,317	Alexandria Real Estate Equities, Inc.	$ 2,746,198
	47,740	American Homes 4 Rent, Class A	2,081,941
	7,518	AvalonBay Communities, Inc.	1,898,972
	54,679	Brixmor Property Group, Inc.	1,389,393
	12,850	Camden Property Trust	2,296,038
	22,132	DigitalRealty Trust, Inc.	3,914,487
	18,699	EastGroup Properties, Inc.	4,260,567
	7,802	Equinix, Inc.	6,599,244
	17,309	Equity LifeStyle Properties, Inc.	1,517,307
	18,216	Extra Space Storage, Inc.	4,130,114
	35,928	First Industrial Realty Trust, Inc.	2,378,434
	35,258	Global Medical REIT, Inc.	625,829
	29,722	Healthcare Trust of America, Inc., Class A	992,418
	10,541	Highwoods Properties, Inc.	470,023
	63,259	Independence Realty Trust, Inc.	1,633,980
	15,913	Innovative Industrial Properties, Inc.	4,183,687
	28,439	iStar, Inc.	734,579
	59,330	Kimco Realty Corp.	1,462,484
	17,551	Life Storage, Inc.	2,688,462
	106,706	Macerich Co.	1,843,880
	74,086	Medical Properties Trust, Inc.	1,750,652
	14,506	Mid-America Apartment Communities, Inc.	3,328,257
	61,915	National Storage Affiliates Trust	4,284,518
	22,185	NexPoint Residential Trust, Inc.	1,859,768
	50,669	Prologis, Inc.	8,530,633
	30,589	Rexford Industrial Realty, Inc.	2,481,074
	8,001(a)	Ryman Hospitality Properties, Inc.	735,772
	33,608	Simon Property Group, Inc.	5,369,550
	21,111	SL Green Realty Corp.	1,513,685
	13,381	Sun Communities, Inc.	2,809,609
	42,897	UDR, Inc.	2,573,391
	9,964	Welltower, Inc.	854,612
		Total Equity Real Estate Investment Trusts (REITs)	$83,939,558
		Hotels, Restaurants & Leisure — 1.1%
	5,755(a)	Airbnb, Inc., Class A	$ 958,150
		Total Hotels, Restaurants & Leisure	$ 958,150
		Real Estate Management & Development — 2.1%
	1,720(a)	Jones Lang LaSalle, Inc.	$ 463,265
	41,990	Newmark Group, Inc., Class A	785,213
	10,482	St Joe Co.	545,588
		Total Real Estate Management & Development	$ 1,794,066


Shares			Value
		TOTAL COMMON STOCKS
		(Cost $55,728,648)	$86,691,774
		SHORT TERM INVESTMENTS — 0.5% of Net Assets
		Open-End Mutual Funds — 0.5%
	462,016	Dreyfus Government Cash Management,
		Institutional Shares, 0.03%(b)	$ 462,016
			$ 462,016
		TOTAL SHORT TERM INVESTMENTS
		(Cost $462,016)	$ 462,016
		TOTAL INVESTMENTS IN UNAFFILIATED ISSUERS — 99.9%
		(Cost $56,190,664)	$87,153,790
		OTHER ASSETS AND LIABILITIES — 0.1%	$ 99,371
		NET ASSETS — 100.0%	$87,253,161

REIT	Real Estate Investment Trust.
(a)	Non-income producing security.
(b)	Rate periodically changes. Rate disclosed is the 7-day yield at December 31, 2021.

Aggregate gross unrealized appreciation for all investments in which
there is an excess of value over tax cost	$31,256,036
Aggregate gross unrealized depreciation for all investments in which
there is an excess of tax cost over value	(478,886)
Net unrealized appreciation	$30,777,150

	Level 1	Level 2	Level 3	Total
Common Stocks	$86,691,774	$ —	$ —	$86,691,774
Open-End Mutual Funds	462,016	—	—	462,016
Total Investments in Securities	$87,153,790	$ —	$ —	$87,153,790

ASSETS:
Investments in unaffiliated issuers, at value (cost $56,190,664)	$87,153,790
Receivables —
Investment securities sold	79,771
Fund shares sold	7,614
Dividends	221,900
Due from the Adviser	2,607
Other assets	16,980
Total assets	$87,482,662
LIABILITIES:
Payables —
Investment securities purchased	$ 48,729
Fund shares repurchased	85,226
Distributions	97
Trustees’ fees	74
Professional fees	48,335
Transfer agent fees	15,064
Shareowner communications expense	6,376
Printing Expense	4,993
Due to affiliates	14,815
Accrued expenses	5,792
Total liabilities	$ 229,501
NET ASSETS:
Paid-in capital	$55,547,169
Distributable earnings	31,705,992
Net assets	$87,253,161
NET ASSET VALUE PER SHARE:
No par value (unlimited number of shares authorized)
Class A (based on $79,065,175/4,449,143 shares)	$ 17.77
Class C (based on $3,997,305/236,183 shares)	$ 16.92
Class Y (based on $4,190,681/236,575 shares)	$ 17.71
MAXIMUM OFFERING PRICE PER SHARE:
Class A (based on $17.77 net asset value per share/100%-5.75%
maximum sales charge)	$ 18.85

Statement of Operations
FOR THE YEAR ENDED 12/31/21

INVESTMENT INCOME:
Dividends from unaffiliated issuers (net of foreign taxes
withheld $(168))	$ 1,402,529
Total Investment Income		$ 1,402,529
EXPENSES:
Management fees	$ 619,859
Administrative expenses	89,732
Transfer agent fees
Class A	110,174
Class C	7,659
Class Y	3,792
Distribution fees
Class A	176,123
Class C	35,540
Shareowner communications expense	40,854
Custodian fees	5,854
Registration fees	55,309
Professional fees	60,013
Printing expense	38,080
Trustees’ fees	7,827
Insurance expense	122
Miscellaneous	13,780
Total expenses		$ 1,264,718
Less fees waived and expenses reimbursed
by the Adviser		(77,854)
Net expenses		$ 1,186,864
Net investment income		$ 215,665
REALIZED AND UNREALIZED GAIN (LOSS)
ON INVESTMENTS:
Net realized gain (loss) on:
Investments in unaffiliated issuers	$12,842,322
Other assets and liabilities denominated in
foreign currencies	16	$12,842,338
Change in net unrealized appreciation (depreciation) on:
Investments in unaffiliated issuers	$13,641,222
Other assets and liabilities denominated in
foreign currencies	(17)	$13,641,205
Net realized and unrealized gain (loss) on investments		$26,483,543
Net increase in net assets resulting from operations		$26,699,208

	Year	Year
	Ended	Ended
	12/31/21	12/31/20
FROM OPERATIONS:
Net investment income (loss)	$ 215,665	$ 507,621
Net realized gain (loss) on investments	12,842,338	(8,528,858)
Change in net unrealized appreciation (depreciation)
on investments	13,641,205	509,531
Net increase (decrease) in net assets resulting
from operations	$ 26,699,208	$ (7,511,706)
DISTRIBUTIONS TO SHAREOWNERS:
Class A ($0.66 and $0.25 per share, respectively)	$ (2,948,218)	$ (1,249,317)
Class C ($0.54 and $0.16 per share, respectively)	(125,010)	(46,647)
Class Y ($0.71 and $0.29 per share, respectively)	(164,988)	(69,988)
Tax return of capital
Class A ($0.00 and $0.13 per share, respectively)	—	(654,008)
Class C ($0.00 and $0.09 per share, respectively)	—	(30,063)
Class Y ($0.00 and $0.13 per share, respectively)	—	(35,645)
Total distributions to shareowners	$ (3,238,216)	$ (2,085,668)
FROM FUND SHARE TRANSACTIONS:
Net proceeds from sales of shares	$ 5,160,791	$ 4,100,292
Reinvestment of distributions	3,184,503	2,041,457
Cost of shares repurchased	(14,108,605)	(18,288,948)
Net decrease in net assets resulting from
Fund share transactions	$ (5,763,311)	$(12,147,199)
Net increase (decease) in net assets	$ 17,697,681	$(21,744,573)
NET ASSETS:
Beginning of year	$ 69,555,480	$ 91,300,053
End of year	$ 87,253,161	$ 69,555,480


A: PWREX	C: PCREX	Y: PYREX

	2021	2020
Distributions paid from:
Ordinary income	$ 703,998	$ 507,397
Long-term capital gain	2,534,218	858,555
Tax return of capital	—	719,716
Total distributions	$3,238,216	$2,085,668

	2021
Distributable earnings/(losses):
Undistributed long-term capital gain	$ 928,842
Net unrealized appreciation	30,777,150
Total	$31,705,992

Shareowner Communications:
Class A	$36,434
Class C	3,458
Class Y	962
Total	$40,854

			Other Directorships
Name, Age and Position	Term of Office and		Held by Trustee During
Held With the Fund	Length of Service	Principal Occupation(s) During At Least The Past Five Years	At Least The Past Five Years
Thomas J. Perna (71)	Trustee since 2006.	Private investor (2004 – 2008 and 2013 – present); Chairman (2008 – 2013)	Director, Broadridge Financial
Chairman of the Board	Serves until a successor	and Chief Executive Officer (2008 – 2012), Quadriserv, Inc. (technology	Solutions, Inc. (investor
and Trustee	trustee is elected or	products for securities lending industry); and Senior Executive Vice	communications and securities
	earlier retirement	President, The Bank of New York (financial and securities services)	processing provider for financial
	or removal.	(1986 – 2004)	services industry) (2009 – present);
			Director, Quadriserv, Inc. (2005 –
			2013); and Commissioner, New
			Jersey State Civil Service
			Commission (2011 – 2015)
John E. Baumgardner, Jr. (70)	Trustee since 2019.	Of Counsel (2019 – present), Partner (1983-2018), Sullivan & Cromwell	Chairman, The Lakeville Journal
Trustee	Serves until a successor	LLP (law firm).	Company, LLC, (privately-held
	trustee is elected or		community newspaper group)
	earlier retirement		(2015-present)
	or removal.
Diane Durnin (64)	Trustee since 2019.	Managing Director - Head of Product Strategy and Development, BNY	None
Trustee	Serves until a successor	Mellon Investment Management (investment management firm) (2012-2018);
	trustee is elected or	Vice Chairman – The Dreyfus Corporation (2005 – 2018): Executive Vice
	earlier retirement	President Head of Product, BNY Mellon Investment Management (2007-2012);
	or removal.	Executive Director- Product Strategy, Mellon Asset Management (2005-2007);
		Executive Vice President Head of Products, Marketing and Client Service,
		Dreyfus Corporation (investment management firm) (2000-2005); and Senior
		Vice President Strategic Product and Business Development, Dreyfus
		Corporation (1994-2000)

Call us for:
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new accounts, prospectuses, applications
and service forms	1-800-225-6292

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account information and transactions	1-800-225-4321

Our internet e-mail address	us.askamundi@amundi.com
(for general questions about Amundi only)

Visit our web site: www.amundi.com/us.

SECTION II - POLICY

SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION		SPECIFIC PRE-APPROVED SERVICE SUBCATEGORIES

I. AUDIT SERVICES	Services that are directly		o Accounting research assistance
	related to performing the		o SEC consultation, registration
	independent audit of the Funds		statements, and reporting
			o Tax accrual related matters
			o Implementation of new accounting standards
			o Compliance letters (e.g. rating agency letters)
			o Regulatory reviews and assistance
			regarding financial matters
			o Semi-annual reviews (if requested)
			o Comfort letters for closed end offerings
II. AUDIT-RELATED	Services which are not		o AICPA attest and agreed-upon procedures
SERVICES	prohibited under Rule		o Technology control assessments
	210.2-01(C)(4) (the “Rule”)		o Financial reporting control assessments
	and are related extensions of		o Enterprise security architecture
	the audit services support the		assessment
	audit, or use the knowledge/expertise
	gained from the audit procedures as a
	foundation to complete the project.
	In most cases, if the Audit-Related
	Services are not performed by the
	Audit firm, the scope of the Audit
	Services would likely increase.
	The Services are typically well-defined
	and governed by accounting
	professional standards (AICPA,
	SEC, etc.)

AUDIT COMMITTEE APPROVAL POLICY		AUDIT COMMITTEE REPORTING POLICY
o “One-time” pre-approval		o A summary of all such
for the audit period for all		services and related fees
pre-approved specific service		reported at each regularly
subcategories. Approval of the		scheduled Audit Committee
independent auditors as		meeting.
auditors for a Fund shall
constitute pre approval for
these services.

o “One-time” pre-approval		o A summary of all such
for the fund fiscal year within		services and related fees
a specified dollar limit		(including comparison to
for all pre-approved		specified dollar limits)
specific service subcategories		reported quarterly.

o Specific approval is
needed to exceed the
pre-approved dollar limit for
these services (see general
Audit Committee approval policy
below for details on obtaining
specific approvals)

o Specific approval is
needed to use the Fund’s
auditors for Audit-Related
Services not denoted as
“pre-approved”, or
to add a specific service
subcategory as “pre-approved”


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PRE-APPROVED SERVICE
		SUBCATEGORIES
III. TAX SERVICES	Services which are not	o Tax planning and support
	prohibited by the Rule,	o Tax controversy assistance
	if an officer of the Fund	o Tax compliance, tax returns, excise
	determines that using the	tax returns and support
	Fund’s auditor to provide	o Tax opinions
	these services creates
	significant synergy in
	the form of efficiency,
	minimized disruption, or
	the ability to maintain a
	desired level of
	confidentiality.


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PROHIBITED SERVICE
		SUBCATEGORIES
PROHIBITED SERVICES	Services which result	1. Bookkeeping or other services
	in the auditors losing	related to the accounting records or
	independence status	financial statements of the audit
	under the Rule.	client*
		2. Financial information systems design
		and implementation*
		3. Appraisal or valuation services,
		fairness* opinions, or
		contribution-in-kind reports
		4. Actuarial services (i.e., setting
		actuarial reserves versus actuarial
		audit work)*
		5. Internal audit outsourcing services*
		6. Management functions or human
		resources
		7. Broker or dealer, investment
		advisor, or investment banking services
		8. Legal services and expert services
		unrelated to the audit
		9. Any other service that the Public
		Company Accounting Oversight Board
		determines, by regulation, is
		impermissible


AUDIT COMMITTEE APPROVAL POLICY	AUDIT COMMITTEE REPORTING POLICY
o These services are not to be	o A summary of all
performed with the exception of the(*)	services and related
services that may be permitted	fees reported at each
if they would not be subject to audit	regularly scheduled
procedures at the audit client (as	Audit Committee meeting
defined in rule 2-01(f)(4)) level	will serve as continual
the firm providing the service.	confirmation that has
	not provided any
	restricted services.