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Neuberger Berman Group LLC

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)


SG 02. Publicly available RI policy or guidance documents (Not Completed)


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Generally, employees of Neuberger Berman’s U.S. based registered investment advisers are subject to the firm’s Code of Ethics (the “Code”).  The Code of Ethics complies with Rule 204A-1 of the Investment Advisers Act (the “Advisers Act”) and Rule 17j-1 of the Investment Company Act (the “Company Act”), which require registered investment advisers and investment companies to adopt and enforce codes of ethics applicable to its supervised persons (as defined in the Code) that include certain provisions regarding standards of business conduct; compliance with applicable federal securities laws; reporting and reviewing of personal securities and holdings; reporting of code violations; and the furnishing and acknowledging of a firm’s code of ethics.

The Code of Ethics contains standards of business conduct based upon established principles, including: (a) placing client interests ahead of employees’ personal interests; (b) refraining from any practice which would operate as a fraud or deceit; (c) conducting personal securities transactions in such a manner as to avoid any actual or potential conflict of interest or any abuse of an individual's position of trust and responsibility; (d) reporting actual and potential conflicts of interest; and (e) maintaining confidentiality of client information.

03.3. Additional information. [Optional]

The Code of Ethics also contains employee trading policies and procedures that are closely monitored by our Legal and Compliance Department.  Key aspects of the employee trading policies and procedures include: (a) requirements for securities accounts to be maintained with the firm or other approved entities; (b) an employee price restitution policy; (c) prohibitions against employee participation in initial public offerings; (d) prohibitions against trading on the basis of material non-public information; (e) pre-approval requirements for certain security transactions such as private placement offerings; (f) minimum holding periods for most personal securities transactions; and (g) annual written affirmation of reporting obligations and compliance with the Code.

The price restitution policy attempts to address the potential conflict that could arise from employees owning the same securities as clients, or where the accounts of both enter the market at the same time. Subject to certain exclusions, employee trades that are executed on the same day and in the same security as a client’s account are reviewed to ensure that the employee does not receive a better price than the client. In the event that the employee does receive a better price, the employee’s price is “switched” to that of the client’s and the cash difference in the execution price is disgorged from the employee account. Disgorged proceeds are often allocated to client accounts in the form of revised execution prices. In some instances, however, a revised execution price may for operational reasons not be feasible and the proceeds will either be remitted to client accounts or donated to charity.

Advisory Persons (as defined by the Code) are subject to a broader review period with respect to their own clients.   There may also be differences in policies within the Code as it relates to Advisory Persons of the NB Mutual Funds with respect to certain employee trading policies and procedures, such as holding periods, blackout periods and price switch/discouragement policies.


SG 04. Identifying incidents occurring within portfolios (Private)


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