Premiums for the Bond have been paid through the period ending April 30, 2025. This filing includes the following exhibits:
Exhibit C - Copy of the Form of Resolutions of a Majority of the Independent Fund Trustees/Directors
Exhibit D - Amount of a Single Insured Bond for each Fund, if a Joint Insured Fidelity Bond were not used
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
1401 H St. NW
Washington, DC 20005
INVESTMENT COMPANY BLANKET BOND
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
1401 H St. NW
Washington, DC 20005
DECLARATIONS
NOTICE
This policy is issued by your risk retention group. Your risk retention group may not be subject to all of the insurance laws and regulations
of your state. State insurance insolvency guaranty funds are not available for your risk retention group.
Item 1.
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Name of Insured (the “Insured”)
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Neuberger Berman Investment Advisers LLC
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Principal Office: |
Mailing Address: |
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1290 Avenue of the America
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1290 Avenue of the Americas
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New York, NY 10104
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Item 2.
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Bond Period: from 12:01 a.m. on
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April 30, 2024
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, to 12:01 a.m. on
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April 30, 2025
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, or
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the earlier effective date of the termination of this Bond, standard time at the Principal Office as to each of said dates. |
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Item 3.
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Limit of Liability—
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Subject to Sections 9, 10 and 12 hereof:
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LIMIT OF
LIABILITY
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DEDUCTIBLE
AMOUNT
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Insuring Agreement A-
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FIDELITY
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$20,000,000
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$150,000
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Insuring Agreement B-
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AUDIT EXPENSE
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$50,000
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$10,000
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Insuring Agreement C-
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ON PREMISES
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$20,000,000
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$150,000
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Insuring Agreement D-
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IN TRANSIT
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$20,000,000
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$150,000
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Insuring Agreement E-
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FORGERY OR ALTERATION
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$20,000,000
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$150,000
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Insuring Agreement F-
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SECURITIES
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$20,000,000
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$150,000
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Insuring Agreement G-
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COUNTERFEIT CURRENCY
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$20,000,000
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$150,000
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Insuring Agreement H-
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UNCOLLECTIBLE ITEMS OF DEPOSIT
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$25,000
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$5,000
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Insuring Agreement I-
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PHONE/ELECTRONIC TRANSACTIONS
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$20,000,000
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$150,000
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If “Not Covered” is inserted opposite any Insuring Agreement above, such Insuring Agreement and any reference thereto shall be deemed to be deleted from this
Bond.
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OPTIONAL INSURING AGREEMENTS ADDED BY RIDER:
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Insuring Agreement J-
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COMPUTER SECURITY
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$20,000,000
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$150,000
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Insuring Agreement M-
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SOCIAL ENGINEERING FRAUD
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$1,000,000
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$150,000
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Item 4. |
Offices or Premises Covered--All the Insured’s offices or other premises in existence at the time this Bond becomes effective
are covered under this Bond, except the offices or other premises excluded by Rider. Offices or other premises acquired or established after the effective date of this Bond are covered subject to the terms of General Agreement A. |
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Item 5. |
The liability of ICI Mutual Insurance Company, a Risk Retention Group (the “Underwriter”) is subject to the terms of the following Riders attached hereto:
Riders: 1-2-3-4-5-6-7-8-9-10-11-12-13-14
and of all Riders applicable to this Bond issued during the Bond Period.
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By: ____/S/ Swenitha Nalli_______________
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By: ____/S/ Catherine Dalton___________
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Authorized Representative
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Authorized Representative
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INVESTMENT COMPANY BLANKET BOND
NOTICE
This policy is issued by your risk retention group. Your risk retention group may not be subject to all of the insurance laws and regulations of your state. State
insurance insolvency guaranty funds are not available for your risk retention group.
ICI Mutual Insurance Company, a Risk Retention Group (the “Underwriter”), in consideration of an agreed premium, and in reliance upon the
Application and all other information furnished to the Underwriter by the Insured, and subject to and in accordance with the Declarations, General Agreements, Provisions, Conditions and Limitations and other terms of this bond (including all riders
hereto) (“Bond”), to the extent of the Limit of Liability and subject to the Deductible Amount, agrees to indemnify the Insured for the loss, as described in the Insuring Agreements, sustained by the Insured at any time but discovered during the
Bond Period.
INSURING AGREEMENTS
Loss resulting directly from any Dishonest or Fraudulent Act committed by an Employee, committed anywhere and whether
committed alone or in collusion with other persons (whether or not Employees), during the time such Employee has the status of an Employee as defined herein, and even if such loss is not discovered until after he or she ceases to be an Employee;
and EXCLUDING loss covered under Insuring Agreement B.
Expense incurred by the Insured for that part of the costs of audits or examinations required by any governmental
regulatory authority or Self-Regulatory Organization to be conducted by such authority or Organization or by an independent accountant or other person, by reason of the discovery of loss sustained by the Insured and covered by this Bond.
Loss of Property resulting directly from any Mysterious Disappearance, or any Dishonest or Fraudulent Act committed by a
person physically present in an office or on the premises of the Insured at the time the Property is surrendered, while the Property is (or reasonably supposed or believed by the Insured to be) lodged or deposited within the Insured’s offices or
premises located anywhere, except those offices excluded by Rider; and EXCLUDING loss covered under Insuring Agreement A.
Loss of Property resulting directly from any Mysterious Disappearance or Dishonest or Fraudulent Act while the Property is
physically (not electronically) in transit anywhere in the custody of any person authorized by an Insured to act as a messenger, except while in the mail or with a carrier for hire (other than a Security Company); and EXCLUDING loss covered under
Insuring Agreement A. Property is “in transit” beginning immediately upon receipt of such Property by the transporting person and ending immediately upon delivery to the designated recipient or its agent, but only while the Property is being
conveyed.
Loss resulting directly from the Insured having, in good faith, paid or transferred any Property in reliance upon any
Written, Original:
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(1) |
bills of exchange, checks, drafts, or other written orders or directions to pay sums certain in money, acceptances, certificates of deposit, due bills, money orders, warrants,
orders upon public treasuries, or letters of credit; or
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(2) |
instructions, requests or applications directed to the Insured, authorizing or acknowledging the transfer, payment, redemption, delivery or receipt of money or Property, or
giving notice of any bank account (provided such instructions or requests or applications purport to have been signed or endorsed by (a) any customer of the Insured, or (b) any shareholder of or subscriber to shares issued by any Investment
Company, or (c) any financial or banking institution or stockbroker, and further provided such instructions, requests, or applications either bear the forged signature or endorsement or have been altered without the knowledge and consent of
such customer, such shareholder or subscriber to shares issued by an Investment Company, or such financial or banking institution or stockbroker); or
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(3) |
withdrawal orders or receipts for the withdrawal of Property, or receipts or certificates of deposit for Property and bearing the name of the Insured as issuer or of another
Investment Company for which the Insured acts as agent;
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which bear (a) a Forgery, or (b) an Alteration, but only to the extent that the Forgery or Alteration directly causes the
loss.
Actual physical possession by the Insured or its authorized representative of the items listed in (1) through (3) above is
a condition precedent to the Insured having relied upon the items.
This Insuring Agreement E does not cover loss caused by Forgery or Alteration of Securities or loss covered under Insuring
Agreement A.
Loss resulting directly from the Insured, in good faith, in the ordinary course of business, and in any capacity
whatsoever, whether for its own account or for the account of others, having acquired, accepted or received, or sold or delivered, or given any value, extended any credit or assumed any liability in reliance on any Written, Original Securities,
where such loss results from the fact that such Securities prove to:
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(1) |
be Counterfeit, but only to the extent that the Counterfeit directly causes the loss, or
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(2) |
be lost or stolen, or
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(3) |
contain a Forgery or Alteration, but only to the extent the Forgery or Alteration directly causes the loss,
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and notwithstanding whether or not the act of the Insured causing such loss violated the constitution, by-laws, rules, or
regulations of any Self-Regulatory Organization, whether or not the Insured was a member thereof.
This Insuring Agreement F does not cover loss covered under Insuring Agreement A.
Actual physical possession by the Insured or its authorized representative of the Securities is a condition precedent to
the Insured having relied upon the Securities.
Loss resulting directly from the receipt by the Insured, in good faith of any Counterfeit Currency.
This Insuring Agreement G does not cover loss covered under Insuring Agreement A.
H. |
UNCOLLECTIBLE ITEMS OF DEPOSIT
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Loss resulting directly from the payment of dividends, issuance of Fund shares or redemptions or exchanges permitted from
an account with the Fund as a consequence of
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(1) |
uncollectible Items of Deposit of a Fund’s customer, shareholder or subscriber credited by the Insured or its agent to such person’s Fund account, or
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(2) |
any Item of Deposit processed through an automated clearing house which is reversed by a Fund’s customer, shareholder or subscriber and is deemed uncollectible by the Insured;
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PROVIDED, that (a) Items of Deposit shall not be deemed uncollectible until the Insured’s collection procedures have
failed, (b) exchanges of shares between Funds with exchange privileges shall be covered hereunder only if all such Funds are insured by the Underwriter for uncollectible Items of Deposit, and (c) the Insured Fund shall have implemented and
maintained a policy to hold Items of Deposit for the minimum number of days stated in its Application (as amended from time to time) before paying any dividend or permitting any withdrawal with respect to such Items of Deposit (other than exchanges
between Funds). Regardless of the number of transactions between Funds in an exchange program, the minimum number of days an Item of Deposit must be held shall begin from the date the Item of Deposit was first credited to any Insured Fund.
This Insuring Agreement H does not cover loss covered under Insuring Agreement A.
I. |
PHONE/ELECTRONIC TRANSACTIONS
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Loss resulting directly from a Phone/Electronic Transaction, where the request for such Phone/Electronic Transaction:
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(1) |
is transmitted to the Insured or its agents by voice over the telephone or by Electronic Transmission; and
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(2) |
is made by an individual purporting to be a Fund shareholder or subscriber or an authorized agent of a Fund shareholder or subscriber; and
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(3) |
is unauthorized or fraudulent and is made with the manifest intent to deceive;
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PROVIDED, that the entity receiving such request generally maintains and follows during the Bond Period all
Phone/Electronic Transaction Security Procedures with respect to all Phone/Electronic Transactions; and
EXCLUDING loss resulting from:
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(1) |
the failure to pay for shares attempted to be purchased; or
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(2) |
any redemption of Investment Company shares which had been improperly credited to a shareholder’s account where such shareholder (a) did not cause, directly or indirectly, such
shares to be credited to such account, and (b) directly or indirectly received any proceeds or other benefit from such redemption; or
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(3) |
any redemption of shares issued by an Investment Company where the proceeds of such redemption were requested (i) to be paid or made payable to other than an Authorized
Recipient or an Authorized Bank Account or (ii) to be sent to other than an Authorized Address;
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(4) |
the intentional failure to adhere to one or more Phone/Electronic Transaction Security Procedures; or
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(5) |
a Phone/Electronic Transaction request transmitted by electronic mail or transmitted by any method not subject to the Phone/Electronic Transaction Security Procedures; or
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(6) |
the failure or circumvention of any physical or electronic protection device, including any firewall, that imposes restrictions on the flow of electronic traffic in or out of
any Computer System.
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This Insuring Agreement I does not cover loss covered under Insuring Agreement A, “Fidelity” or Insuring Agreement J,
“Computer Security”.
GENERAL AGREEMENTS
A. |
ADDITIONAL OFFICES OR EMPLOYEES—CONSOLIDATION OR MERGER—NOTICE
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1. |
Except as provided in paragraph 2 below, this Bond shall apply to any additional office(s) established by the Insured during the Bond Period and to all Employees during the Bond Period, without the
need to give notice thereof or pay additional premiums to the Underwriter for the Bond Period.
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2. |
If during the Bond Period an Insured Investment Company shall merge or consolidate with an institution in which such Insured is the surviving entity, or purchase substantially
all the assets or capital stock of another institution, or acquire or create a separate investment portfolio, and shall within sixty (60) days notify the Underwriter thereof, then this Bond shall automatically apply to the Property and
Employees resulting from such merger, consolidation, acquisition or creation from the date thereof; provided, that the Underwriter may make such coverage contingent upon the payment of an additional premium.
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No statement made by or on behalf of the Insured, whether contained in the Application or otherwise, shall be deemed to be
an absolute warranty, but only a warranty that such statement is true to the best of the knowledge of the person responsible for such statement.
C. |
COURT COSTS AND ATTORNEYS’ FEES |
The Underwriter will indemnify the Insured against court costs and reasonable attorneys’ fees incurred and paid by the
Insured in defense of any legal proceeding brought against the Insured seeking recovery for any loss which, if established against the Insured, would constitute a loss covered under the terms of this Bond; provided, however, that with respect to
Insuring Agreement A this indemnity shall apply only in the event that:
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1. |
an Employee admits to having committed or is adjudicated to have committed a Dishonest or Fraudulent Act which caused the loss; or
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2. |
in the absence of such an admission or adjudication, an arbitrator or arbitrators acceptable to the Insured and the Underwriter concludes, after a review of an agreed statement
of facts, that an Employee has committed a Dishonest or Fraudulent Act which caused the loss.
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The Insured shall promptly give notice to the Underwriter of any such legal proceeding and upon request shall furnish the
Underwriter with copies of all pleadings and other papers therein. At the Underwriter’s election the Insured shall permit the Underwriter to conduct the defense of such legal proceeding in the Insured’s name, through attorneys of the Underwriter’s
selection. In such event, the Insured shall give all reasonable information and assistance which the Underwriter shall deem necessary to the proper defense of such legal proceeding.
If the amount of the Insured’s liability or alleged liability in any such legal proceeding is greater than the amount
which the Insured would be entitled to recover under this Bond (other than pursuant to this General Agreement C), or if a Deductible Amount is applicable, or both, the indemnity liability of the Underwriter under this General Agreement C is limited
to the proportion of court costs and attorneys’ fees incurred and paid by the Insured or by the Underwriter that the amount which the Insured would be entitled to recover under this Bond (other than pursuant to this General Agreement C) bears to
the sum of such amount plus the amount which the Insured is not entitled to recover. Such indemnity shall be in addition to the Limit of Liability for the applicable Insuring Agreement.
This Bond shall be interpreted with due regard to the purpose of fidelity bonding under Rule 17g-1 under the Investment Company Act of 1940
(i.e., to protect innocent third parties from harm) and to the structure of the investment management industry (in which a loss of Property resulting from a cause described in any Insuring Agreement ordinarily gives rise to a potential legal
liability on the part of the Insured), such that the term “loss” as used herein shall include an Insured’s legal liability for direct compensatory damages resulting directly from a misappropriation, or measurable diminution in value, of Property.
THIS BOND, INCLUDING THE FOREGOING INSURING AGREEMENTS
AND GENERAL AGREEMENTS, IS SUBJECT TO THE FOLLOWING
PROVISIONS, CONDITIONS AND LIMITATIONS:
SECTION 1. DEFINITIONS
The following terms used in this Bond shall have the meanings stated in this Section:
A.
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“Alteration” means the marking,
changing or altering in a material way of the terms, meaning or legal effect of a document with the intent to deceive.
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B.
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“Application” means the
Insured’s application (and any attachments and materials submitted in connection therewith) furnished to the Underwriter for this Bond.
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C.
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“Authorized Address” means (1)
any Officially Designated address to which redemption proceeds may be sent, (2) any address designated in writing (not to include Electronic Transmission) by the Shareholder of Record and received by the Insured at least one (1) day
prior to the effective date of such designation, or (3) any address designated by voice over the telephone or by Electronic Transmission by the Shareholder of Record at least 15 days prior to the effective date of such designation.
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D.
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“Authorized Bank Account” means
any Officially Designated bank account to which redemption proceeds may be sent.
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E.
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“Authorized Recipient” means
(1) the Shareholder of Record, or (2) any other Officially Designated person to whom redemption proceeds may be sent.
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F.
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“Computer System” means (1)
computers with related peripheral components, including storage components, (2) systems and applications software, (3) terminal devices, (4) related communications networks or customer communication systems, and (5) related electronic
funds transfer systems; by which data or monies are electronically collected, transmitted, processed, stored or retrieved.
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G.
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“Convertible Virtual Currency” means Digital Assets that have an equivalent value in real currency, or
that act as a substitute for real currency, including, without limitation, stablecoins and other cryptocurrency.
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H.
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“Counterfeit” means a Written imitation of an actual
valid Original which is intended to deceive and to be taken as the Original.
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I.
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“Currency” means a medium of
exchange in current use authorized or adopted by a domestic or foreign government as part of its official currency.
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J.
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“Deductible Amount” means, with
respect to any Insuring Agreement, the amount set forth under the heading “Deductible Amount” in Item 3 of the Declarations or in any Rider for such Insuring Agreement, applicable to each Single Loss covered by such Insuring Agreement.
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K.
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“Depository” means any
“securities depository” (other than any foreign securities depository) in which an Investment Company may deposit its Securities in accordance with Rule 17f-4 under the Investment Company Act of 1940.
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L.
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“Digital Assets” mean any digital representations of value which are recorded
on cryptographically secured distributed ledgers or any similar technology, including, without limitation, Convertible Virtual Currency and Non-Fungible Tokens.
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M.
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“Dishonest or Fraudulent Act”
means any dishonest or fraudulent act, including “larceny and embezzlement” as defined in Section 37 of the Investment Company Act of 1940, committed with the conscious manifest intent (1) to cause the Insured to sustain a loss and (2)
to obtain an improper financial benefit for the perpetrator or any other person or entity. A Dishonest or Fraudulent Act does not mean or include a reckless act, a negligent act, or a grossly negligent act. As used in this definition,
“improper financial benefit” does not include any employee benefits received in the course of employment, including salaries, commissions, fees, bonuses, promotions, awards, profit sharing or pensions.
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N.
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“Electronic Transmission” means
any transmission effected by electronic means, including but not limited to a transmission effected by telephone tones, Telefacsimile, wireless device, or over the Internet.
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(1) |
each officer, director, trustee, partner or employee of the Insured, and
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(2) |
each officer, director, trustee, partner or employee of any predecessor of the Insured whose principal assets are acquired by the Insured by consolidation or merger with, or
purchase of assets or capital stock of, such predecessor, and
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(3) |
each attorney performing legal services for the Insured and each employee of such attorney or of the law firm of such attorney while performing services for the Insured, and
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(4) |
each student who is an authorized intern of the Insured, while in any of the Insured’s offices, and
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(5) |
each officer, director, trustee, partner or employee of
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(a) |
an investment adviser,
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(b) |
an underwriter (distributor),
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(c) |
a transfer agent or shareholder accounting recordkeeper, or
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(d) |
an administrator authorized by written agreement to keep financial and/or other required records,
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for an Investment Company named as an Insured, BUT ONLY while (i) such officer, partner or employee is performing acts
coming within the scope of the usual duties of an officer or employee of an Insured, or (ii) such officer, director, trustee, partner or employee is acting as a member of any committee duly elected or appointed to examine or audit or have custody
of or access to the Property of the Insured, or (iii) such director or trustee (or anyone acting in a similar capacity) is acting outside the scope of the usual duties of a director or trustee; PROVIDED, that the term “Employee” shall not include
any officer, director, trustee, partner or employee of a transfer agent, shareholder accounting recordkeeper or administrator (x) which is not an “affiliated person” (as defined in Section 2(a) of the Investment Company Act of 1940) of an
Investment Company named as an Insured or of the adviser or underwriter of such Investment Company, or (y) which is a “Bank” (as defined in Section 2(a) of the Investment Company Act of 1940), and
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(6) |
each individual assigned, by contract or by any agency furnishing temporary personnel, in either case on a contingent or part-time basis, to perform the usual duties of an
employee in any office of the Insured, and
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(7) |
each individual assigned to perform the usual duties of an employee or officer of any entity authorized by written agreement with the Insured to perform services as electronic
data processor of checks or other accounting records of the Insured, but excluding a processor which acts as transfer agent or in any other agency capacity for the Insured in issuing checks, drafts or securities, unless included under
subsection (5) hereof, and
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(8) |
each officer, partner or employee of
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(a) |
any Depository or Exchange,
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(b) |
any nominee in whose name is registered any Security included in the systems for the central handling of securities established and maintained by any Depository, and
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(c) |
any recognized service company which provides clerks or other personnel to any Depository or Exchange on a contract basis,
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while such officer, partner or employee is performing services for any Depository in the operation of systems for the central handling of
securities, and
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(9) |
in the case of an Insured which is an “employee benefit plan” (as defined in Section 3 of the Employee Retirement Income Security Act of 1974 (“ERISA”)) for officers, directors
or employees of another Insured (“In-House Plan”), any “fiduciary” or other “plan official” (within the meaning of Section 412 of ERISA) of such In-House Plan, provided that such fiduciary or other plan official is a director, partner,
officer, trustee or employee of an Insured (other than an In-House Plan).
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Each employer of temporary personnel and each entity referred to in subsections (6) and (7) and their respective partners,
officers and employees shall collectively be deemed to be one person for all the purposes of this Bond.
Brokers, agents, independent contractors, or representatives of the same general character shall not be considered
Employees, except as provided in subsections (3), (6), and (7).
P.
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“Exchange” means any national
securities exchange registered under the Securities Exchange Act of 1934.
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Q.
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“Forgery” means the physical
signing on a document of the name of another person with the intent to deceive. A Forgery may be by means of mechanically reproduced facsimile signatures as well as handwritten signatures. Forgery does not include the signing of an
individual’s own name, regardless of such individual’s authority, capacity or purpose.
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R.
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“Items of Deposit” means one or
more checks or drafts.
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S.
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“Investment Company” or “Fund” means an investment company registered under the Investment Company Act of 1940.
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T.
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“Limit of Liability” means,
with respect to any Insuring Agreement, the limit of liability of the Underwriter for any Single Loss covered by such Insuring Agreement as set forth under the heading “Limit of Liability” in Item 3 of the Declarations or in any Rider
for such Insuring Agreement.
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U.
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“Mysterious Disappearance”
means any disappearance of Property which, after a reasonable investigation has been conducted, cannot be explained.
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V.
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“Non-Fund” means any
corporation, business trust, partnership, trust or other entity which is not an Investment Company.
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W.
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“Non-Fungible Tokens” mean Digital Assets that are unique digital identifiers
that are recorded on cryptographically secured distributed ledgers or any similar technology, and that are used to certify authenticity and/or ownership of unique assets that cannot be traded, divided, or exchanged at equivalency.
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X.
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“Officially Designated” means
designated by the Shareholder of Record:
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(1) |
in the initial account application,
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(2) |
in writing accompanied by a signature guarantee, or
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(3) |
in writing or by Electronic Transmission, where such designation is verified via a callback to the Shareholder of Record by the Insured at a predetermined telephone number
provided by the Shareholder of Record to the Insured in writing at least 30 days prior to such callback.
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Y.
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“Original” means the first
rendering or archetype and does not include photocopies or electronic transmissions even if received and printed.
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Z.
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“Phone/Electronic Transaction”
means any (1) redemption of shares issued by an Investment Company, (2) election concerning dividend options available to Fund shareholders, (3) exchange of shares in a registered account of one Fund into shares in an identically
registered account of another Fund in the same complex pursuant to exchange privileges of the two Funds, or (4) purchase of shares issued by an Investment Company, which redemption, election, exchange or purchase is requested by voice
over the telephone or through an Electronic Transmission.
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AA.
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“Phone/Electronic Transaction Security Procedures” means security procedures for Phone/
Electronic Transactions as set forth in the Application and/or as otherwise provided in writing to the Underwriter.
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BB.
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“Property” means the following
tangible items: money, postage and revenue stamps, precious metals, Securities, bills of exchange, acceptances, checks, drafts, or other written orders or directions to pay sums certain in money, certificates of deposit, due bills,
money orders, letters of credit, financial futures contracts, conditional sales contracts, abstracts of title, insurance policies, deeds, mortgages, and assignments of any of the foregoing, and other valuable papers, including books of
account and other records used by the Insured in the conduct of its business, and all other instruments similar to or in the nature of the foregoing (but excluding all data processing records), (1) in which the Insured has a legally
cognizable interest, (2) in which the Insured acquired or should have acquired such an interest by reason of a predecessor’s declared financial condition at the time of the Insured’s consolidation or merger with, or purchase of the
principal assets of, such predecessor or (3) which are held by the Insured for any purpose or in any capacity.
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CC.
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“Securities” means original
negotiable or non-negotiable agreements or instruments which represent an equitable or legal interest, ownership or debt (including stock certificates, bonds, promissory notes, and assignments thereof), which are in the ordinary course
of business transferable by physical delivery with appropriate endorsement or assignment. “Securities” does not include bills of exchange, acceptances, certificates of deposit, checks, drafts, or other written orders or directions to
pay sums certain in money, due bills, money orders, or letters of credit.
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DD.
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“Security Company” means an
entity which provides or purports to provide the transport of Property by secure means, including, without limitation, by use of armored vehicles or guards.
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EE.
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“Self-Regulatory Organization”
means any association of investment advisers or securities dealers registered under the federal securities laws, or any Exchange.
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FF.
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“Shareholder of Record” means
the record owner of shares issued by an Investment Company or, in the case of joint ownership of such shares, all record owners, as designated (1) in the initial account application, or (2) in writing accompanied by a signature
guarantee, or (3) pursuant to procedures as set forth in the Application and/or as otherwise provided in writing to the Underwriter.
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(1) |
all loss caused by any one act (other than a Dishonest or Fraudulent Act) committed by one person, or
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(2) |
all loss caused by Dishonest or Fraudulent Acts committed by one person, or
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(3) |
all expenses incurred with respect to any one audit or examination, or
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(4) |
all loss caused by any one occurrence or event other than those specified in subsections (1) through (3) above.
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All acts or omissions of one or more persons which directly or indirectly aid or, by failure to report or otherwise,
permit the continuation of an act referred to in subsections (1) and (2) above of any other person shall be deemed to be the acts of such other person for purposes of this subsection.
All acts or occurrences or events which have as a common nexus any fact, circumstance, situation, transaction or series of
facts, circumstances, situations, or transactions shall be deemed to be one act, one occurrence, or one event.
HH.
|
“Telefacsimile” means a system
of transmitting and reproducing fixed graphic material (as, for example, printing) by means of signals transmitted over telephone lines or over the Internet.
|
II.
|
“Written” means expressed
through letters or marks placed upon paper and visible to the eye.
|
SECTION 2. EXCLUSIONS
THIS BOND DOES NOT COVER:
A. |
Loss resulting from (1) riot or civil commotion outside the United States of America and Canada, or (2) war, revolution, insurrection, action by armed forces, or usurped power,
wherever occurring; except if such loss occurs while the Property is in transit, is otherwise covered under Insuring Agreement D, and when such transit was initiated, the Insured or any person initiating such transit on the Insured’s behalf
had no knowledge of such riot, civil commotion, war, revolution, insurrection, action by armed forces, or usurped power.
|
B.
|
Loss in time of peace or war resulting from nuclear fission or fusion or radioactivity, or biological or chemical agents or
hazards, or fire, smoke, or explosion, or the effects of any of the foregoing.
|
C.
|
Loss resulting from any Dishonest or Fraudulent Act committed by any person while acting in the capacity of a member of the Board
of Directors or any equivalent body of the Insured or of any other entity.
|
D.
|
Loss resulting from any nonpayment or other default of any loan or similar transaction made by the Insured or any of its partners,
directors, officers or employees, whether or not authorized and whether procured in good faith or through a Dishonest or Fraudulent Act, unless such loss is otherwise covered under Insuring Agreement A, E, or F.
|
E.
|
Loss resulting from any violation by the Insured or by any Employee of any law, or any rule or regulation pursuant thereto or
adopted by a Self-Regulatory Organization, regulating the issuance, purchase or sale of securities, securities transactions upon security exchanges or over the counter markets, Investment Companies, or investment advisers, unless such
loss, in the absence of such law, rule or regulation, would be covered under Insuring Agreement A, E, or F.
|
F.
|
Loss resulting from Property that is the object of a Dishonest or Fraudulent Act or Mysterious Disappearance while in the custody
of any Security Company, unless such loss is covered under this Bond and is in excess of the amount recovered or received by the Insured under (1) the Insured’s contract with such Security Company, and (2) insurance or indemnity of any
kind carried by such Security Company for the benefit of, or otherwise available to, users of its service, in which case this Bond shall cover only such excess, subject to the applicable Limit of Liability and Deductible Amount.
|
G.
|
Potential income, including but not limited to interest and dividends, not realized by the Insured because of a loss covered under
this Bond, except when covered under Insuring Agreement H.
|
H.
|
Loss in the form of (1) damages of any type for which the Insured is legally liable, except direct compensatory damages, or (2)
taxes, fines, or penalties, including without limitation two-thirds of treble damage awards pursuant to judgments under any statute or regulation.
|
I.
|
Loss resulting from the surrender of Property away from an office of the Insured as a result of kidnap, ransom, or extortion, or a
threat
|
|
(1) |
to do bodily harm to any person, except where the Property is in transit in the custody of any person acting as messenger as a result of a threat to do bodily harm to such
person, if the Insured had no knowledge of such threat at the time such transit was initiated, or
|
|
(2) |
to do damage to the premises or Property of the Insured,
|
unless such loss is otherwise covered under Insuring Agreement A.
J.
|
All costs, fees, and other expenses incurred by the Insured in establishing the existence of or amount of loss covered under this
Bond, except to the extent certain audit expenses are covered under Insuring Agreement B.
|
K.
|
Loss resulting from payments made to or withdrawals from any account, involving funds erroneously credited to such account, unless
such loss is otherwise covered under Insuring Agreement A.
|
L.
|
Loss resulting from uncollectible Items of Deposit which are drawn upon a financial institution outside the United States of
America, its territories and possessions, or Canada.
|
M.
|
Loss resulting from the Dishonest or Fraudulent Acts or other acts or omissions of an Employee primarily engaged in the sale of
shares issued by an Investment Company to persons other than (1) a person registered as a broker under the Securities Exchange Act of 1934 or (2) an “accredited investor” as defined in Rule 501(a) of Regulation D under the Securities Act
of 1933, which is not an individual.
|
N.
|
Loss resulting from the use of credit, debit, charge, access, convenience, identification, cash management or other cards, whether
such cards were issued or purport to have been issued by the Insured or by anyone else, unless such loss is otherwise covered under Insuring Agreement A.
|
O.
|
Loss resulting from any purchase, redemption or exchange of securities issued by an Investment Company or other Insured, or any
other instruction, request, acknowledgement, notice or transaction involving securities issued by an Investment Company or other Insured or the dividends in respect thereof, when any of the foregoing is requested, authorized or directed
or purported to be requested, authorized or directed by voice over the telephone or by Electronic Transmission, unless such loss is otherwise covered under Insuring Agreement A or Insuring Agreement I.
|
P.
|
Loss resulting from any Dishonest or Fraudulent Act or committed by an Employee as defined in Section 1.O(2), unless such loss (1)
could not have been reasonably discovered by the due diligence of the Insured at or prior to the time of acquisition by the Insured of the assets acquired from a predecessor, and (2) arose out of a lawsuit or valid claim brought against
the Insured by a person unaffiliated with the Insured or with any person affiliated with the Insured.
|
Q.
|
Loss resulting from the unauthorized entry of data into, or the deletion or destruction of data in, or the change of data elements
or programs within, any Computer System, unless such loss is otherwise covered under Insuring Agreement A.
|
R.
|
Loss resulting from the theft, disappearance, destruction, disclosure, or unauthorized use of confidential or personal information
(including, but not limited to, trade secrets, personal shareholder or client information, shareholder or client lists, personally identifiable financial or medical information, intellectual property, or any other type of non-public
information), whether such information is owned by the Insured or held by the Insured in any capacity (including concurrently with another person); provided, however, this exclusion shall not apply to loss arising out of the use of such
information to support or facilitate the commission of an act otherwise covered by this Bond.
|
S.
|
All costs, fees, and other expenses arising from a data security breach or incident, including, but not limited to, forensic audit
expenses, fines, penalties, expenses to comply with federal and state laws and expenses related to notifying affected individuals.
|
T.
|
Loss resulting from vandalism or malicious mischief.
|
U.
|
Loss resulting from the theft, disappearance, or destruction of Digital Assets or from the change in value of Digital Assets,
unless such loss (1) is sustained by any investment company registered under the Investment Company Act of 1940 that is named as an Insured and (2) is otherwise covered under Insuring Agreement A.
|
SECTION 3. ASSIGNMENT OF RIGHTS
Upon payment to the Insured hereunder for any loss, the Underwriter shall be subrogated to the extent of such payment to
all of the Insured’s rights and claims in connection with such loss; provided, however, that the Underwriter shall not be subrogated to any such rights or claims one named Insured under this Bond may have against another named Insured under this
Bond. At the request of the Underwriter, the Insured shall execute all assignments or other documents and take such action as the Underwriter may deem necessary or desirable to secure and perfect such rights and claims, including the execution of
documents necessary to enable the Underwriter to bring suit in the name of the Insured.
Assignment of any rights or claims under this Bond shall not bind the Underwriter without the Underwriter’s written
consent.
SECTION 4. LOSS—NOTICE—PROOF—LEGAL
PROCEEDINGS
This Bond is for the use and benefit only of the Insured and the Underwriter shall not be liable hereunder to anyone other
than the Insured. As soon as practicable and not more than sixty (60) days after discovery of any loss covered hereunder, the Insured shall give the Underwriter written notice thereof and, as soon as practicable and within one year after such
discovery, shall also furnish to the Underwriter affirmative proof of loss with full particulars. The Underwriter may extend the sixty-day notice period or the one-year proof of loss period if the Insured requests an extension and shows good cause
therefor.
The Insured shall provide the Underwriter with such information, assistance, and cooperation as the Underwriter may
reasonably request.
See also General Agreement C (Court Costs and Attorneys’ Fees).
The Underwriter shall not be liable hereunder for loss of Securities unless each of the Securities is identified in such
proof of loss by a certificate or bond number or by such identification means as the Underwriter may require. The Underwriter shall have a reasonable period after receipt of a proper affirmative proof of loss within which to investigate the claim,
but where the Property is Securities and the loss is clear and undisputed, settlement shall be made within forty-eight (48) hours even if the loss involves Securities of which duplicates may be obtained.
The Insured shall not bring legal proceedings against the Underwriter to recover any loss hereunder prior to sixty (60)
days after filing such proof of loss or subsequent to twenty-four (24) months after the discovery of such loss or, in the case of a legal proceeding to recover hereunder on account of any judgment against the Insured in or settlement of any suit
mentioned in General Agreement C or to recover court costs or attorneys’ fees paid in any such suit, twenty-four (24) months after the date of the final judgment in or settlement of such suit. If any limitation in this Bond is prohibited by any
applicable law, such limitation shall be deemed to be amended to be equal to the minimum period of limitation permitted by such law.
Notice hereunder shall be given to Manager, Professional Liability Claims, ICI Mutual Insurance Company, RRG, 1401 H
St. NW, Washington, DC 20005, with an electronic copy to LegalSupport@icimutual.com.
SECTION 5. DISCOVERY
For all purposes under this Bond, a loss is discovered, and discovery of a loss occurs, when the Insured
|
(1) |
becomes aware of facts, or
|
|
(2) |
receives notice of an actual or potential claim by a third party which alleges that the Insured is liable under circumstances,
|
which would cause a reasonable person to assume that a loss of a type covered by this Bond has been or is likely to be
incurred, regardless of when the act or acts causing or contributing to such loss occurred, even though the exact amount or details of the loss may not be known.
SECTION 6. VALUATION OF PROPERTY
For the purpose of determining the amount of any loss hereunder, the value of any Property shall be the market value of
such Property at the close of business on the first business day before the discovery of such loss; except that
|
(1) |
the value of any Property replaced by the Insured prior to the payment of a claim therefor shall be the actual market value of such Property at the time of replacement, but not
in excess of the market value of such Property on the first business day before the discovery of the loss of such Property;
|
|
(2) |
the value of Securities which must be produced to exercise subscription, conversion, redemption or deposit privileges shall be the market value of such privileges immediately
preceding the expiration thereof if the loss of such Securities is not discovered until after such expiration, but if there is no quoted or other ascertainable market price for such Property or privileges referred to in clauses (1) and (2),
their value shall be fixed by agreement between the parties or by arbitration before an arbitrator or arbitrators acceptable to the parties; and
|
|
(3) |
the value of books of accounts or other records used by the Insured in the conduct of its business shall be limited to the actual cost of blank books, blank pages or other
materials if the books or records are reproduced plus the cost of labor for the transcription or copying of data furnished by the Insured for reproduction.
|
SECTION 7. LOST SECURITIES
The maximum liability of the Underwriter hereunder for lost Securities
shall be the payment for, or replacement of, such Securities having an aggregate value not to exceed the applicable Limit of Liability. If the Underwriter shall make payment to the Insured for any loss of Securities, the Insured shall assign to the Underwriter all of the Insured’s right, title and interest in and to such Securities. In lieu of such payment, the Underwriter may, at its option, replace such lost
Securities, and in such case the Insured shall cooperate to effect such replacement. To effect the replacement of lost Securities, the Underwriter may issue or arrange for the issuance of a lost instrument bond. If the value of such Securities
does not exceed the applicable Deductible Amount (at the time of the discovery of the loss), the Insured will pay the usual premium charged for the lost instrument bond and will indemnify the issuer of such bond against all loss and expense
that it may sustain because of the issuance of such bond.
If the value of such Securities exceeds the applicable Deductible Amount (at the time of discovery of the loss), the
Insured will pay a proportion of the usual premium charged for the lost instrument bond, equal to the percentage that the applicable Deductible Amount bears to the value of such Securities upon discovery of the loss, and will indemnify the issuer
of such bond against all loss and expense that is not recovered from the Underwriter under the terms and conditions of this Bond, subject to the applicable Limit of Liability.
SECTION 8. SALVAGE
If any recovery is made, whether by the Insured or the Underwriter, on account of any loss within the applicable Limit of
Liability hereunder, the Underwriter shall be entitled to the full amount of such recovery to reimburse the Underwriter for all amounts paid hereunder with respect to such loss. If any recovery is made, whether by the Insured or the Underwriter, on
account of any loss in excess of the applicable Limit of Liability hereunder plus the Deductible Amount applicable to such loss from any source other than suretyship, insurance, reinsurance, security or indemnity taken by or for the benefit of the
Underwriter, the amount of such recovery, net of the actual costs and expenses of recovery, shall
be applied to reimburse the Insured in full for the portion of such loss in excess of such Limit of Liability, and the
remainder, if any, shall be paid first to reimburse the Underwriter for all amounts paid hereunder with respect to such loss and then to the Insured to the extent of the portion of such loss within the Deductible Amount. The Insured shall execute
all documents which the Underwriter deems necessary or desirable to secure to the Underwriter the rights provided for herein.
SECTION 9. |
NON-REDUCTION AND NON-ACCUMULATION OF LIABILITY AND TOTAL LIABILITY
|
Prior to its termination, this Bond shall continue in force up to the Limit of Liability for each Insuring Agreement for
each Single Loss, notwithstanding any previous loss (other than such Single Loss) for which the Underwriter may have paid or be liable to pay hereunder; PROVIDED, however, that regardless of the number of years this Bond shall continue in force and
the number of premiums which shall be payable or paid, the liability of the Underwriter under this Bond with respect to any Single Loss shall be limited to the applicable Limit of Liability irrespective of the total amount of such Single Loss and
shall not be cumulative in amounts from year to year or from period to period.
SECTION 10. |
MAXIMUM LIABILITY OF UNDERWRITER; OTHER BONDS OR POLICIES
|
The maximum liability of the Underwriter for any Single Loss covered by any Insuring Agreement under this Bond shall be
the Limit of Liability applicable to such Insuring Agreement, subject to the applicable Deductible Amount and the other provisions of this Bond. Recovery for any Single Loss may not be made under more than one Insuring Agreement. If any Single Loss
covered under this Bond is recoverable or recovered in whole or in part because of an unexpired discovery period under any other bonds or policies issued by the Underwriter to the Insured or to any predecessor in interest of the Insured, the
maximum liability of the Underwriter shall be the greater of either (1) the applicable Limit of Liability under this Bond, or (2) the maximum liability of the Underwriter under such other bonds or policies.
SECTION 11. |
OTHER INSURANCE
|
Notwithstanding anything to the contrary herein, if any loss covered by this Bond shall also be covered by other insurance
or suretyship for the benefit of the Insured, the Underwriter shall be liable hereunder only for the portion of such loss in excess of the amount recoverable under such other insurance or suretyship, but not exceeding the applicable Limit of
Liability of this Bond.
SECTION 12. |
DEDUCTIBLE AMOUNT
|
The Underwriter shall not be liable under any Insuring Agreement unless the amount of the loss covered thereunder, after
deducting the net amount of all reimbursement and/or recovery received by the Insured with respect to such loss (other than from any other bond, suretyship or insurance policy or as an advance by the Underwriter hereunder) shall exceed the
applicable Deductible Amount; in such case the Underwriter shall be liable only for such excess, subject to the applicable Limit of Liability and the other terms of this Bond.
No Deductible Amount shall apply to any loss covered under Insuring Agreement A sustained by any Investment Company named
as an Insured.
The Underwriter may terminate this Bond as to any Insured or all Insureds only by written notice to such Insured or
Insureds and, if this Bond is terminated as to any Investment Company, to each such Investment Company terminated thereby and to the Securities and Exchange Commission, Washington, D.C., in all cases not less than sixty (60) days prior to the
effective date of termination specified in such notice.
The Insured may terminate this Bond only by written notice to the Underwriter not less than sixty (60) days prior to the
effective date of the termination specified in such notice. Notwithstanding the foregoing, when the Insured terminates this Bond as to any Investment Company, the effective date of termination shall be not less than sixty (60) days from the date
the Underwriter provides written notice of the termination to each such Investment Company terminated thereby and to the Securities and Exchange Commission, Washington, D.C.
This Bond will terminate as to any Insured that is a Non-Fund immediately and without notice upon (1) the takeover of such
Insured’s business by any State or Federal official or agency, or by any receiver or liquidator, or (2) the filing of a petition under any State or Federal statute relative to bankruptcy or reorganization of the Insured, or assignment for the
benefit of creditors of the Insured.
Premiums are earned until the effective date of termination. The Underwriter shall refund the unearned premium computed at
short rates in accordance with the Underwriter’s standard short rate cancellation tables if this Bond is terminated by the Insured or pro rata if this Bond is terminated by the Underwriter.
Upon the detection by any Insured that an Employee has committed any Dishonest or Fraudulent Act(s), the Insured shall
immediately remove such Employee from a position that may enable such Employee to cause the Insured to suffer a loss by any subsequent Dishonest or Fraudulent Act(s). The Insured, within two (2) business days of such detection, shall notify the
Underwriter with full and complete particulars of the detected Dishonest or Fraudulent Act(s).
For purposes of this section, detection occurs when any partner, officer, or supervisory employee of any Insured, who is
not in collusion with such Employee, becomes aware that the Employee has committed any Dishonest or Fraudulent Act(s).
This Bond shall terminate as to any Employee by written notice from the Underwriter to each Insured and, if such Employee
is an Employee of an Insured Investment Company, to the Securities and Exchange Commission, in all cases not less than sixty (60) days prior to the effective date of termination specified in such notice.
SECTION 14. |
RIGHTS AFTER TERMINATION
|
At any time prior to the effective date of termination of this Bond as to any Insured, such Insured may, by written notice
to the Underwriter, elect to purchase the right under this Bond to an additional period of twelve (12) months within which to discover loss sustained by such Insured prior to the effective date of such termination and shall pay an additional
premium therefor as the Underwriter may require.
Such additional discovery period shall terminate immediately and without notice upon the takeover of such Insured’s
business by any State or Federal official or agency, or by any receiver or liquidator. Promptly after such termination the Underwriter shall refund to the Insured any unearned premium.
The right to purchase such additional discovery period may not be exercised by any State or Federal official or agency, or
by any receiver or liquidator, acting or appointed to take over the Insured’s business.
SECTION 15. |
CENTRAL HANDLING OF SECURITIES
|
The Underwriter shall not be liable for loss in connection with the central handling of securities within the systems
established and maintained by any Depository (“Systems”), unless the amount of such loss exceeds the amount recoverable or recovered under any bond or policy or participants’ fund insuring the Depository against such loss (the “Depository’s
Recovery”); in such case the Underwriter shall be liable hereunder only for the Insured’s share of such excess loss, subject to the applicable Limit of Liability, the Deductible Amount and the other terms of this Bond.
For determining the Insured’s share of such excess loss, (1) the Insured shall be deemed to have an interest in any
certificate representing any security included within the Systems equivalent to the interest the Insured then has in all certificates representing the same security included within the Systems; (2) the Depository shall have reasonably and fairly
apportioned the Depository’s Recovery among all those having an interest as recorded by appropriate entries in the books and records of the Depository in Property involved in such loss, so that each such interest shall share in the Depository’s
Recovery in the ratio that the value of each such interest bears to the total value of all such interests; and (3) the Insured’s share of such excess loss shall be the amount of the Insured’s interest in such Property in excess of the amount(s) so
apportioned to the Insured by the Depository.
This Bond does not afford coverage in favor of any Depository or Exchange or any nominee in whose name is registered any
security included within the Systems.
SECTION 16. |
ADDITIONAL COMPANIES INCLUDED AS INSURED
|
If more than one entity is named as the Insured:
|
A. |
the total liability of the Underwriter hereunder for each Single Loss shall not exceed the Limit of Liability which would be applicable if there were only one named Insured,
regardless of the number of Insured entities which sustain loss as a result of such Single Loss,
|
|
B. |
the Insured first named in Item 1 of the Declarations shall be deemed authorized to make, adjust, and settle, and receive and enforce payment of, all claims hereunder as the
agent of each other Insured for such purposes and for the giving or receiving of any notice required or permitted to be given hereunder; provided, that the Underwriter shall promptly furnish each named Insured Investment Company with (1) a
copy of this Bond and any amendments thereto, (2) a copy of each formal filing of a claim hereunder by any other Insured, and (3) notification of the terms of the settlement of each such claim prior to the execution of such settlement,
|
|
C. |
the Underwriter shall not be responsible or have any liability for the proper application by the Insured first named in Item 1 of the Declarations of any payment made hereunder
to the first named Insured,
|
|
D. |
for the purposes of Sections 4 and 13, knowledge possessed or discovery made by any partner, officer or supervisory Employee of any Insured shall constitute knowledge or
discovery by every named Insured,
|
|
E. |
if the first named Insured ceases for any reason to be covered under this Bond, then the Insured next named shall thereafter be considered as the first named Insured for the
purposes of this Bond, and
|
|
F. |
each named Insured shall constitute “the Insured” for all purposes of this Bond.
|
SECTION 17. |
NOTICE AND CHANGE OF CONTROL
|
Within thirty (30) days after learning that there has been a change in control of an Insured by transfer of its
outstanding voting securities the Insured shall give written notice to the Underwriter of:
|
A. |
the names of the transferors and transferees (or the names of the beneficial owners if the voting securities are registered in another name), and
|
|
B. |
the total number of voting securities owned by the transferors and the transferees (or the beneficial owners), both immediately before and after the transfer, and
|
|
C. |
the total number of outstanding voting securities.
|
As used in this Section, “control” means the power to exercise a controlling influence over the management or policies of
the Insured.
SECTION 18. |
CHANGE OR MODIFICATION
|
This Bond may only be modified by written Rider forming a part hereof over the signature of the Underwriter’s authorized
representative. Any Rider which modifies the coverage provided by Insuring Agreement A, Fidelity, in a manner which adversely affects the rights of an Insured Investment Company shall not become effective until at least sixty (60) days after the
Underwriter has given written notice thereof to the Securities and Exchange Commission, Washington, D.C., and to each Insured Investment Company affected thereby.
SECTION 19. |
COMPLIANCE WITH APPLICABLE TRADE AND ECONOMIC SANCTIONS
|
This Bond shall not be deemed to provide any coverage, and the Underwriter shall not be required to pay any loss or
provide any benefit hereunder, to the extent that the provision of such coverage, payment of such loss or provision of such benefit would cause the Underwriter to be in violation of any applicable trade or economic sanctions, laws or regulations,
including, but not limited to, any sanctions, laws or regulations administered and enforced by the U.S. Department of Treasury Office of Foreign Assets Control (OFAC).
SECTION 20. |
ANTI-BUNDLING
|
If any Insuring Agreement requires that an enumerated type of document be Counterfeit, or contain a Forgery or Alteration,
the Counterfeit, Forgery, or Alteration must be on or of the enumerated document itself, not on or of some other document submitted with, accompanying or incorporated by reference into the enumerated document.
IN WITNESS WHEREOF, the Underwriter has caused this Bond to be executed on the Declarations Page.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 1
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
|
AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
|
|
|
In consideration of the premium charged for this Bond, it is hereby understood and agreed that Item 1 of the Declarations, Name of Insured, shall include (subject
to the operation of and restrictions contained within the “Insurance Regulatory Compliance for Non-U.S. Operations Rider”) the following:
Neuberger Berman Asia Limited
Neuberger Berman BD LLC
Neuberger Berman Investment Advisers LLC
Neuberger Berman Europe Limited
Neuberger Berman Advisers Management Trust, a series fund consisting of:
o
|
Mid Cap Growth Portfolio
|
o
|
Mid Cap Intrinsic Value Portfolio
|
o
|
Short Duration Bond Portfolio
|
o
|
Sustainable Equity Portfolio
|
Neuberger Berman Equity Funds, a series fund consisting of:
o
|
Neuberger Berman Dividend Growth Fund
|
o
|
Neuberger Berman Emerging Markets Equity Fund
|
o
|
Neuberger Berman Equity Income Fund
|
o
|
Neuberger Berman Focus Fund
|
o
|
Neuberger Berman Genesis Fund
|
o
|
Neuberger Berman International Equity Fund
|
o
|
Neuberger Berman International Select Fund
|
o
|
Neuberger Berman International Small Cap Fund
|
o
|
Neuberger Berman Intrinsic Value Fund
|
o
|
Neuberger Berman Large Cap Growth Fund
|
o
|
Neuberger Berman Large Cap Value Fund
|
o
|
Neuberger Berman Mid Cap Growth Fund
|
o
|
Neuberger Berman Mid Cap Intrinsic Value Fund
|
o
|
Neuberger Berman Multi-Cap Opportunities Fund
|
o
|
Neuberger Berman Real Estate Fund
|
o
|
Neuberger Berman Small Cap Growth Fund
|
o
|
Neuberger Berman Sustainable Equity Fund
|
o
|
Neuberger Berman U.S. Equity Impact Fund
|
Neuberger Berman Income Funds, a series fund consisting of:
o
|
Neuberger Berman Core Bond Fund
|
o
|
Neuberger Berman Emerging Markets Debt Fund
|
o
|
Neuberger Berman Floating Rate Income Fund
|
o
|
Neuberger Berman High Income Bond Fund
|
o
|
Neuberger Berman Municipal High Income Fund
|
o
|
Neuberger Berman Municipal Impact Fund
|
o
|
Neuberger Berman Municipal Intermediate Bond Fund
|
o
|
Neuberger Berman Short Duration Bond Fund
|
o
|
Neuberger Berman Strategic Income Fund
|
Neuberger Berman Alternative Funds, a series fund consisting of:
o
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
o
|
Neuberger Berman Long Short Fund
|
Neuberger Berman ETF Trust, a series fund consisting of:
o
|
Cayman Commodity Fund I
|
o
|
Neuberger Berman Carbon Transition & Infrastructure ETF
|
o
|
Neuberger Berman China Equity ETF
|
o
|
Neuberger Berman Commodity Strategy ETF
|
o
|
Neuberger Berman Core Equity ETF
|
o
|
Neuberger Berman Disrupters ETF
|
o
|
Neuberger Berman Flexible Credit Income ETF
|
o
|
Neuberger Berman Global Real Estate ETF
|
o
|
Neuberger Berman Next Generation Connected Consumer ETF
|
o |
Neuberger Berman Option Strategy ETF |
o
|
Neuberger Berman Short Duration Income ETF
|
o |
Neuberger Berman Small-Mid Cap ETF |
Neuberger Berman Energy Infrastructure and Income Fund Inc.
Neuberger Berman High Yield Strategies Fund Inc.
Neuberger Berman Municipal Fund Inc.
Neuberger Berman Next Generation Connectivity Fund Inc.
Neuberger Berman Real Estate Securities Income Fund Inc.
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 2
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
|
AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that this Bond (other than Insuring Agreements C and D) does not cover loss resulting from or in connection with any business,
activities, or acts or omissions of (including services rendered by) any Insured which is not an Insured Fund (“Non-Fund Insured”) or any Employee of a Non-Fund Insured, except loss, otherwise covered by the terms of this Bond, resulting from or in connection with (1) services rendered by a Non-Fund Insured to an Insured Fund, or to shareholders of such Fund
in connection with the issuance, transfer, or redemption of their Fund shares, or (2) in the case of a Non-Fund Insured substantially all of whose business is rendering the services described in (1) above, the general business, activities or
operations of such Non-Fund Insured, excluding (a) the rendering of services (other than those described in (1) above) to any person, or (b) the sale of goods or property of any kind.
It is further understood and agreed that with respect to any Non-Fund Insured, Insuring Agreements C and D only cover loss of Property which a Non-Fund Insured
uses or holds, or in which a Non-Fund Insured has an interest, in each case wholly or partially in connection with the rendering of services by a Non-Fund Insured to an Insured Fund, or to shareholders of such Fund in connection with the issuance,
transfer, or redemption of their Fund shares.
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
RN0003.0-02 (07/20)
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 3
INSURED
Neuberger Berman Investment Advisers LLC
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BOND NUMBER
87164124B
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April 30, 2024
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BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that the exclusion set forth at Section 2.M of this Bond shall not apply with respect to loss resulting from the Dishonest or
Fraudulent Acts or other acts or omissions of an Employee in connection with offers or sales of securities issued by an Insured Fund if such Employee (a) is an employee of that Fund or of its investment adviser, principal underwriter, or affiliated
transfer agent, and (b) is communicating with purchasers of such securities only in person in an office of an Insured or by telephone or in writing, and (c) does not receive commissions on such sales; provided,
that such Dishonest or Fraudulent Acts or other acts or omissions do not involve, and such loss does not arise from, a statement or representation which is not (1) contained in a
currently effective prospectus or statement of additional information regarding such securities, which has been filed with the Securities and Exchange Commission, or (2) made as part of a scripted response to a question regarding that Fund or such
securities, if the script has been filed with, and not objected to by, the Financial Industry Regulatory Authority, Inc.; and if the entire scripted response has been read to the caller, and if any response concerning the performance of such
securities is not outdated.
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 4
INSURED
Neuberger Berman Investment Advisers LLC
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BOND NUMBER
87164124B
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April 30, 2024
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BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that the Deductible Amount for Insuring Agreement E, Forgery or Alteration, and Insuring Agreement F, Securities, shall not apply with respect to loss through
Forgery of a signature on the following documents:
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(1) |
letter requesting redemption of $100,000 or less payable by check to the Shareholder of Record and sent to an Authorized Address; or
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(2) |
letter requesting redemption of $100,000 or less by wire transfer to the Shareholder of Record of an Authorized Bank Account; or
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(3) |
written request to a trustee or custodian for a Designated Retirement Account (“DRA”) which holds shares of an Insured Fund, where such request (a) purports to be from or at the instruction of the
Owner of such DRA, and (b) directs such trustee or custodian to transfer $100,000 or less from such DRA to a trustee or custodian for another DRA established for the benefit of such Owner;
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provided, that the Limit of Liability for a Single Loss as described above shall be $100,000 and that the
Insured shall bear 20% of each such loss. This Rider shall not apply in the case of any such Single Loss which exceeds $100,000; in such case the Deductible Amounts and Limits of Liability set forth in Item 3 of the Declarations shall control.
For purposes of this Rider:
|
(A) |
“Designated Retirement Account” means any retirement plan or account described or qualified under the Internal Revenue Code of 1986, as amended, or a subaccount thereof.
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(B) |
“Owner” means the individual for whose benefit the DRA, or a subaccount thereof, is established.
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Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 5
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
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BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
|
|
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that this Bond does not cover any loss resulting from or in connection with the acceptance of any Third Party Check, unless
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(1) |
such Third Party Check is used to open or increase an account which is registered in the name of one or more of the payees on such Third Party Check, and
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(2) |
reasonable efforts are made by the Insured, or by the entity receiving Third Party Checks on behalf of the Insured, to verify all endorsements on all Third Party Checks made payable in amounts
greater than $100,000 (provided, however, that the isolated failure to make such efforts in a particular instance will not preclude coverage, subject to the exclusions herein and in the Bond),
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and then only to the extent such loss is otherwise covered under this Bond.
For purposes of this Rider, “Third Party Check” means a check made payable to one or more parties and offered as payment to one or more other parties.
It is further understood and agreed that notwithstanding anything to the contrary above or elsewhere in the Bond, this Bond does not cover any loss resulting from
or in connection with the acceptance of a Third Party Check where:
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(1) |
any payee on such Third Party Check reasonably appears to be a corporation or other entity; or
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(2) |
such Third Party Check is made payable in an amount greater than $100,000 and does not include the purported endorsements of all payees on such Third Party Check.
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It is further understood and agreed that this Rider shall not apply with respect to any coverage that may be available under Insuring Agreement A, “Fidelity.”
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
RN0030.0-01 (01/02)
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 6
INSURED
Neuberger Berman Investment Advisers LLC
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BOND NUMBER
87164124B
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April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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NEWLY CREATED INVESTMENT COMPANIES
In consideration of the premium charged for this Bond, it is hereby understood and agreed that, notwithstanding anything to the contrary in General Agreement A of
this Bond, Item 1 of the Declarations shall include any Newly Created Investment Company, provided that the Underwriter receives, at least annually, a report that lists (1) all Newly Created Investment Companies created over the preceding twelve
months, and (2) the estimated net assets of each Newly Created Investment Company as of the date of the report.
For purposes of this Rider, “Newly Created Investment Company” shall mean any Investment Company or series thereof (notwithstanding that such Investment Company’s
or series’ registration under the Investment Company Act of 1940 may not yet be effective), which Investment Company or series (1) was not yet created as of the inception of the Bond Period, and (2) has (or upon registration will have) directors
who are identical to the directors of another Insured Fund (other than another Newly Created Investment Company).
It is further understood and agreed that the title in this Rider is included solely for convenience and shall not itself be deemed to be a term or condition of
coverage, or a description or interpretation thereof.
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 7
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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In consideration for the premium charged for this Bond, it is hereby understood and agreed that notwithstanding anything to the contrary in this Bond (including Insuring Agreement I), this Bond does not cover any
loss resulting from any Online Redemption(s) or Online Purchase(s) involving an aggregate amount in excess of Five Hundred Thousand Dollars ($500,000) per shareholder account per day, unless before such redemption(s) or purchase(s), in a procedure
initiated by the Insured or by the entity receiving the request for such Online Redemption(s) or Online Purchase(s):
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(a) |
the Shareholder of Record verifies, by some method other than an Electronic Transmission effected over the Internet, that each such redemption or purchase has been authorized, and
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(b) |
if such redemption or purchase is to be effected by wire to or from a particular bank account, a duly authorized employee of the bank verifies the account number to or from which funds are being
transferred, and that the name on the account is the same as the name of the intended recipient of the proceeds.
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It is further understood and agreed that, notwithstanding the Limit of Liability set forth herein or any other provision of this Bond, the Limit of Liability with
respect to any Single Loss caused by an Online Transaction shall be Twenty Million Dollars ($20,000,000) and the Deductible Amount applicable to any such Single
Loss is One Hundred Fifty Thousand Dollars ($150,000).
It is further understood and agreed that, notwithstanding Section 9, Non-Reduction and Non-Accumulation of Liability and Total Liability, or any other provision of
this Bond, the Aggregate Limit of Liability of the Underwriter under this Bond with respect to any and all loss or losses caused by Online Transactions shall be an aggregate of Twenty Million Dollars ($20,000,000) for the Bond Period, irrespective of the total amount of such loss or losses.
For purposes of this Rider, the following terms shall have the following meanings:
“Online Purchase” means any purchase of shares issued by an Investment Company, which purchase is requested through an Electronic Transmission over the Internet.
“Online Redemption” means any redemption of shares issued by an Investment Company, which redemption is requested through an Electronic Transmission over the
Internet.
“Online Transaction” means any Phone/Electronic Transaction requested through an Electronic Transmission over the Internet.
Except as above stated, nothing herein shall be held to alter, waive, or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 8
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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In consideration for the premium charged for this Bond, it is hereby understood and agreed that, with respect to Insuring Agreement I only, the Deductible Amount set forth in Item 3 of the Declarations
(“Phone/Electronic Deductible”) shall not apply with respect to a Single Loss, otherwise covered by Insuring Agreement I, caused by:
(1)
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a Phone/Electronic Redemption requested to be paid or made payable by check to the Shareholder of Record and sent to an Authorized Address; or
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(2)
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a Phone/Electronic Redemption requested to be paid or made payable by wire transfer to the Shareholder of Record at an Authorized Bank Account,
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provided, that the Limit of Liability for a Single Loss as described in (1) or (2) above shall be the lesser
of 80% of such loss or $80,000 and that the Insured shall bear the remainder of each such Loss. This Rider shall not apply if the application of the Phone/Electronic Deductible to the Single Loss would result
in coverage of greater than $80,000; in such case the Phone/Electronic Deductible and Limit of Liability set forth in Item 3 of the Declarations shall control.
For purposes of this Rider, “Phone/Electronic Redemption” means any redemption of shares
issued by an Investment Company, which redemption is requested (a) by voice over the telephone, (b) through an automated telephone tone or voice response system, (c)
by Telefacsimile, or (d) by transmission over the Internet.
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 9
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
|
|
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that Section 1.N. Definition of Employee is amended to include
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“(10) |
each individual assigned temporarily by an Insured to perform the usual duties of an employee in any office of the Insured provided that such an individual has successfully completed a background
check consisting of all of the following:
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(a) contacting previous employers,
(b) contacting personal references, and
(c) utilizing private investigation agency”
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 10
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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Most property and casualty insurers, including ICI Mutual Insurance Company, a Risk Retention Group (“ICI Mutual”), are subject to the requirements of the Terrorism Risk Insurance Act of 2002, as amended (the “Act”).
The Act establishes a federal insurance backstop under which ICI Mutual and these other insurers may be partially reimbursed by the United States Government for future “insured
losses” resulting from certified “acts of terrorism.” (Each of these bolded terms is defined
by the Act.) The Act also places certain disclosure and other obligations on ICI Mutual and these other insurers.
Pursuant to the Act, any future losses to ICI Mutual caused by certified “acts of terrorism” may be partially reimbursed
by the United Sates government under a formula established by the Act. Under this formula, the United States government would generally reimburse ICI Mutual for the Federal Share of Compensation of ICI Mutual’s “insured
losses” in excess of ICI Mutual’s “insurer deductible” until total “insured losses” of all participating insurers reach $100 billion (the “Cap on Annual
Liability”). If total “insured losses” of all property and casualty insurers reach the Cap on Annual Liability in any one calendar year, the Act limits U.S. Government reimbursement and provides that the
insurers will not be liable under their policies for their portions of such losses that exceed such amount. Amounts otherwise payable under this Bond may be reduced as a result.
This Bond has no express exclusion for “acts of terrorism.” However, coverage under this Bond remains subject to all
applicable terms, conditions, and limitations of the Bond (including exclusions) that are permissible under the Act.
The portion of the premium that is attributable to any coverage potentially available under the Bond for “acts of terrorism”
is one percent (1%) and does not include any charges for the portion of loss that may be covered by the U.S. Government under the Act
As used herein, “Federal Share of Compensation” shall mean 80% beginning on January 1, 2020.
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 11
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
|
AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that the sixth paragraph of Section 13 of this Bond is amended to read as follows:
“For purposes of this section, detection occurs when the Chief Executive Officer, Chief Compliance Officer, Chief Financial
Officer, Chief Legal Officer, Chief Operating Officer, who is not in collusion with such Employee, becomes aware that the Employee has committed any Dishonest or Fraudulent Act(s).”
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 12
INSURED
Neuberger Berman Investment Advisers LLC
|
BOND NUMBER
87164124B
|
April 30, 2024
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BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
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In consideration of the premium charged for this Bond, it is hereby understood and agreed that notwithstanding Section 2.Q of this Bond, this Bond is amended by adding an additional Insuring Agreement J as follows:
J. COMPUTER SECURITY
Loss (including loss of Property) resulting directly from Computer Fraud; provided, that the Insured has adopted in writing and generally maintains and
follows during the Bond Period all Computer Security Procedures. The isolated failure of the Insured to maintain and follow a particular Computer Security Procedure in a particular instance will not preclude coverage under this Insuring Agreement,
subject to the specific exclusions herein and in the Bond.
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1. |
Definitions. The following terms used in this Insuring Agreement shall have the following meanings:
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a. |
“Authorized User” means any person or entity designated by the Insured (through contract, assignment of User Identification, or otherwise) as authorized to use a Covered Computer System, or any
part thereof. An individual who invests in an Insured Fund shall not be considered to be an Authorized User solely by virtue of being an investor.
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b. |
“Computer Fraud” means the unauthorized entry of data into, or the deletion or destruction of data in, or change of data elements or programs within, a Covered Computer System which:
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(1) |
is committed by any Unauthorized Third Party anywhere, alone or in collusion with other Unauthorized Third Parties; and
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(2) |
is committed with the conscious manifest intent (a) to cause the Insured to sustain a loss, and (b) to obtain financial benefit for the perpetrator or any other person; and
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(3) |
causes (x) Property to be transferred, paid or delivered; or (y) an account of the Insured, or of its customer, to be added, deleted, debited or credited; or (z) an unauthorized or
fictitious account to be debited or credited.
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c. |
“Computer Security Procedures” means procedures for prevention of unauthorized computer access and use and administration of computer access and use as provided in writing to the Underwriter.
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d. |
“Covered Computer System” means any Computer System as to which the Insured has possession, custody and control.
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e. |
“Unauthorized Third Party” means any person or entity that, at the time of the Computer Fraud, is not an Authorized User.
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f. |
“User Identification” means any unique user name (i.e., a series of characters) that is assigned to a person or entity by the Insured.
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2. |
Exclusions. It is further understood and agreed that this Insuring Agreement J shall not cover:
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|
a. |
Any loss covered under Insuring Agreement A, “Fidelity,” of this Bond; and
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b. |
Any loss resulting from the intentional failure to adhere to one or more Computer Security Procedures; and
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c. |
Any loss resulting from a Computer Fraud committed by or in collusion with:
|
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(1) |
any Authorized User (whether a natural person or an entity); or
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(2) |
in the case of any Authorized User which is an entity, (a) any director, officer, partner, employee or agent of such Authorized User, or (b) any entity which controls, is controlled by, or is under
common control with such Authorized User (“Related Entity”), or (c) any director, officer, partner, employee or agent of such Related Entity; or
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(3) |
in the case of any Authorized User who is a natural person, (a) any entity for which such Authorized User is a director, officer, partner, employee or agent (“Employer Entity”), or (b) any
director, officer, partner, employee or agent of such Employer Entity, or (c) any entity which controls, is controlled by, or is under common control with such Employer Entity (“Employer-Related Entity”), or (d) any director, officer,
partner, employee or agent of such Employer-Related Entity;
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and
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d. |
Any loss resulting from physical damage to or destruction of any Covered Computer System, or any part thereof, or any data, data elements or media associated therewith; and
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e. |
Any loss not directly and proximately caused by Computer Fraud (including, without limitation, disruption of business and extra expense); and
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f. |
Payments made to any person(s) who has threatened to deny or has denied authorized access to a Covered Computer System or otherwise has threatened to disrupt the business of the Insured.
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For purposes of this Insuring Agreement, “Single Loss,” as defined in Section 1.GG of this Bond, shall also include all loss caused by Computer Fraud(s) committed
by one person, or in which one person is implicated, whether or not that person is specifically identified. A series of losses involving unidentified individuals, but arising from the same method of operation, may be deemed by the Underwriter to
involve the same individual and in that event shall be treated as a Single Loss.
It is further understood and agreed that nothing in this Rider shall affect the exclusion set forth in Section 2.O of this Bond.
Coverage under this Insuring Agreement shall terminate upon termination of this Bond. Coverage under this Insuring Agreement may also be terminated without
terminating this Bond as an entirety:
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(a) |
by written notice from the Underwriter not less than sixty (60) days prior to the effective date of termination specified in such notice; or
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(b) |
immediately by written notice from the Insured to the Underwriter.
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Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 13
INSURED
Neuberger Berman Investment Advisers LLC
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BOND NUMBER
87164124B
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April 30, 2024
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BOND PERIOD
April 30, 2024 to April 30, 2025
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AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
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SOCIAL ENGINEERING FRAUD
In consideration of the premium charged for this Bond, it is hereby understood and agreed that this Bond is amended by adding an additional Insuring Agreement M,
as follows:
M. Social Engineering Fraud
Loss resulting directly from the Insured, in good faith, transferring, paying, or delivering money from its own account as a direct result of a Social Engineering
Fraud;
PROVIDED, that the entity receiving such request generally maintains and follows during the Bond Period all Social Engineering Security Procedures.
The Limit of Liability for a Single Loss under this Insuring Agreement M shall be the lesser of (a) 50% of the amount by which such Single Loss exceeds the
Deductible Amount or (b) $1,000,000 (One Million Dollars), and the Insured shall bear the remainder of any such Single Loss. The Deductible Amount for this Insuring Agreement M is $150,000 (One Hundred Fifty Thousand Dollars).
Notwithstanding any other provision of this Bond, the aggregate Limit of Liability under this Bond with respect to any and all loss or losses under this Insuring
Agreement M shall be $1,000,000 (One Million Dollars) for the Bond Period, irrespective of the total amount of such loss or losses.
This Insuring Agreement M does not cover loss covered under any other Insuring Agreement of this Bond.
It is further understood and agreed that for purposes of this rider:
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1. |
“Communication” means an instruction that (a) directs an Employee to transfer, pay, or deliver money from the Insured’s own account, (b) contains a material misrepresentation of fact, and (c) is
relied upon by the Employee, believing it to be true.
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2. |
“Social Engineering Fraud” means the intentional misleading of an Employee through the use of a Communication, where such Communication:
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(a) |
is transmitted to the Employee in writing, by voice over the telephone, or by Electronic Transmission;
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(b) |
is made by an individual who purports to be (i) an Employee who is duly authorized by the Insured to instruct another Employee to transfer, pay, or deliver money, or (ii) an officer or employee of
a Vendor who is duly authorized by the Insured to instruct an Employee to transfer, pay, or deliver money; and
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(c) |
is unauthorized, dishonest or fraudulent and is made with the manifest intent to deceive.
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3. |
“Social Engineering Security Procedures” means security procedures intended to prevent Social Engineering Fraud as set forth in the Application and/or as otherwise provided in writing to the
Underwriter.
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4. |
“Vendor” means any entity or individual that provides goods or services to the Insured under a pre-existing, written agreement.
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Except as above stated, nothing herein shall be held to alter, waive, or extend any of the terms of this Bond.
ICI MUTUAL INSURANCE COMPANY,
a Risk Retention Group
INVESTMENT COMPANY BLANKET BOND
RIDER NO. 14
INSURED
Neuberger Berman Investment Advisers LLC
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BOND NUMBER
87164124B
|
April 30, 2024
|
BOND PERIOD
April 30, 2024 to April 30, 2025
|
AUTHORIZED REPRESENTATIVE
/S/ Catherine Dalton
|
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INSURANCE REGULATORY COMPLIANCE FOR NON-U.S. OPERATIONS RIDER
In consideration of the premium charged for this Bond, it is hereby understood and agreed as follows:
1. |
Interpretation: This rider shall be interpreted with due regard to the intention of the
parties, which is to provide specified Bond coverage to (a) Foreign Entities and (b) U.S. Entities for Financial Interest Losses, where permitted, subject to adherence to applicable laws and regulations.
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2. |
Compliance with Applicable Laws and Regulations of Foreign Jurisdictions Regarding Use of Non-Admitted Insurance: Notwithstanding that one or more Foreign Entities may be included in the definition of “Insured” in Item 1 of the Declarations (as modified by Rider No. 1 or other rider), this Bond does not insure, and the
Underwriter shall not be required to pay any loss sustained by, or to provide any benefit hereunder to or on behalf of, any Foreign Entity if doing so would cause the Underwriter or such Foreign Entity or any Insured to be in violation of
applicable laws or regulations of any Associated Foreign Jurisdiction regarding the use of Non-Admitted Insurance or the making or acceptance of payments thereunder (“Prohibited Associated Foreign Jurisdiction”). Examples of Prohibited
Associated Foreign Jurisdictions to which this Part 2 applies shall include but not be limited to the following jurisdictions: Japan, Brazil, India, and China.
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3. |
Financial Interest Loss Coverage Extension: If permissible pursuant to applicable laws and regulations, a Financial Interest Loss incurred by a U.S. Entity shall be deemed to be a loss sustained by such U.S. Entity for purposes of Section 10 (“Maximum
Liability of Underwriter; Other Bonds or Policies”) of this Bond, such that coverage under this Bond may extend to a U.S. Entity for its Financial Interest Loss, subject to all of the terms, conditions and limitations of this Bond
(including all terms, conditions and limitations of this rider).
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4. |
Good Faith Efforts to Resolve Questions: In the event that issues arise regarding the application of Part 2 or Part 3 of this rider in the context of a particular situation, representatives of the Underwriter and of a U.S. Entity (acting on behalf of a Foreign Entity if
the issue involves Part 2, or on behalf of the U.S. Entity if the issue involves Part 3) shall seek in good faith to resolve such issues to their mutual satisfaction. If the representatives cannot reach a mutually acceptable resolution on
their own, they shall in good faith consider soliciting expert outside
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guidance to assist them in resolving the issues, with the costs and fees of such expert to be shared equally as between the Underwriter and the
U.S. Entity. If the representatives are unable to resolve the issues following these good faith efforts to do so, nothing herein shall preclude the U.S. Entity or the Underwriter from thereafter commencing a judicial proceeding to
resolve the issues, provided, however, that such a proceeding (i) may not be commenced earlier than ninety (90) days after the representatives have completed the good faith efforts described herein, and (ii) must be in compliance with
Part 5.d of this rider.
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a. |
Locally Admitted Insurance: Without otherwise limiting Section 11 (“Other Insurance”) of this Bond or the terms (including, without limitation, Parts 2 and 3) of this rider, any coverage that may otherwise be available under this rider and
this Bond for (1) any loss sustained by any Foreign Entity, and/or (2) any Financial Interest Loss sustained by any U.S. Entity, shall be specifically excess of, and shall not contribute with, any coverage available under any Locally
Admitted Insurance. A Foreign Entity or U.S. Entity may, however, credit any amount recovered under any Locally Admitted Insurance against the Deductible Amount applicable to a related loss or Financial Interest Loss for which coverage is
available under this Bond and this rider, provided that such recovered amount constitutes loss for which coverage would otherwise have been available under the terms of both this rider and Bond.
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b. |
U.S. Entity as Representative: Notwithstanding anything to the contrary in the first
paragraph of Section 4 of this Bond, unless otherwise agreed to by the Underwriter in writing: (1) a U.S. Entity shall act on behalf of all Foreign Entities with respect to all information or payments provided to or by the Underwriter
under this Bond; (2) a Foreign Entity shall have no right to provide any such information or payments directly to, or to receive any such information or payments directly from, the Underwriter; and (3) the Underwriter shall have no
obligation to receive any information or payments directly from, or to provide any such information or payments directly to, any Foreign Entity. The “information or payments” referenced above shall include, without limitation: notice and
an affirmative proof of loss under Section 4 of this Bond; notice of termination under Section 13 of this Bond; notice of a change in control under Section 17 of this Bond; information, assistance, and cooperation to the Underwriter with
regard to the Application or any Bond claim; premiums payable and any return premiums that may be due under this Bond; any loss that may be payable under this Bond; any riders issued to form a part of this Bond; and the exercising or
declining the exercise of any right to a discovery period under Section 14 of this Bond.
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c. |
Treatment of Financial Interest Loss: As the context and logic may demand or suggest, the duties, obligations and rights of Insureds and the Underwriter under this Bond with regard to a loss shall be deemed to apply to a U.S. Entity with regard to a
Financial Interest Loss. Thus, by way of illustration, and without limitation:
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(1) |
Duties and Obligations of a U.S. Entity: Bond provisions obligating Insureds to provide
notice and proof of loss (Section 4), to reimburse the Underwriter for a recovery (Section 8), and to take action upon detection that an Employee has committed any Dishonest or Fraudulent Act(s) (Section 13), shall apply to a U.S. Entity
with respect to any matter involving a Foreign Entity that may result in a Financial Interest Loss.
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(2) |
Deductibles: Bond provisions regarding Deductible Amounts (Section 12) shall apply to a
Financial Interest Loss.
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(3) |
Discovery Period: Bond provisions affording Insureds with rights to a discovery period
(Section 14) shall apply to a U.S. Entity with respect to any matter involving a Foreign Entity that may result in a Financial Interest Loss.
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(4) |
Sanctions: Bond provisions relating to violations of applicable trade or economic
sanctions, laws or regulations (Section 19) shall apply to a Financial Interest Loss.
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d. |
Actions Against the Underwriter: No action involving any Foreign Entity as a party, or
otherwise relating to any Foreign Entity, may be brought against the Underwriter anywhere other than in a court within the State of Vermont in the United States of America. In the case of any such action, this policy shall be governed by
and construed and enforced only in accordance with the internal laws of the State of Vermont (without reference to choice of law doctrine applicable in such state), and the English text as it appears in this Bond.
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e. |
Definition of “Fund” or “Investment Company”: With regard to loss sustained by a Foreign
Entity or a Financial Interest Loss, the term “Fund” or “Investment Company,” except as used in Sections 12, 13, 16, and 18 of this Bond, shall be deemed to include any Foreign Entity that is a Foreign Fund.
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f. |
Definition of “Self-Regulatory Organization”: With regard to loss sustained by a Foreign
Entity or a Financial Interest Loss, the term “Self-Regulatory Organization,” as used in Insuring Agreement B., Audit Expense, Insuring Agreement F.,
Securities, and Section 2.E of this Bond only, shall be deemed to include any association or organization of investment advisers or securities dealers registered or authorized under the securities laws of a Foreign Jurisdiction or any
securities exchange registered with any Foreign Jurisdiction.
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g. |
Termination: Notwithstanding anything to the contrary in Section 13 (“Termination”) or any
other provision of this Bond, this Bond shall terminate immediately as to any Foreign Entity without prior notice to such Foreign Entity:
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(1) |
if there is a change in control (as defined in Section 17 of this Bond) of such Foreign Entity by transfer of its outstanding voting securities or otherwise, or
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(2) |
if such Foreign Entity shall merge or consolidate with an entity such that the Foreign Entity is the surviving entity, or purchase or otherwise acquire any other entity or substantially all the
assets of another entity, or acquire or create a Subsidiary or separate investment portfolio,
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unless, prior to such change in control, or merger or consolidation, or purchase, or
acquisition or creation, respectively (“Event”), the Foreign Entity notifies the Underwriter in writing of the impending Event and the Underwriter, in its sole discretion, determines to continue the Bond upon such terms and conditions as the
Underwriter may deem appropriate.
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h. |
Title and Headings: The title and headings in this rider are included solely for
convenience and shall not themselves be deemed to be terms or conditions of coverage, or descriptions or interpretations thereof.
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6. Definitions: As used in this rider:
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a. |
“Associated Foreign Jurisdiction” means a Foreign Jurisdiction in which a Foreign Entity is (1) organized; (2) domiciled; or (3) is operating or conducting business.
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b. |
“Financial Interest Loss” means the actual financial loss that a U.S. Entity itself sustains from Foreign Entity Loss incurred by a Foreign Entity, which financial loss is sustained by the U.S.
Entity solely and directly as a result of:
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(1) |
its financial interest in such Foreign Entity; and/or
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(2) |
any lawful pre-existing obligation it has to indemnify such Foreign Entity for all or part of such Foreign Entity Loss.
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For the purposes of this Bond the amount of a Financial Interest Loss shall be capped at the amount of the relevant associated Foreign Entity
Loss.
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c. |
“Foreign Entity” means:
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(1) |
any Non-Fund included as an Insured in Item No. 1 of the Declarations (as modified by Rider No. 1 or other rider) that (i) is a Subsidiary of a U.S. Entity, (ii) is organized or domiciled in a
Foreign Jurisdiction, and (iii) is not a Foreign Fund;
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(2) |
any Foreign Fund included as an “Insured” in Item No. 1 of the Declarations (as modified by Rider No. 1 or other rider); and
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(3) |
a U.S. Entity, but only insofar as such U.S. Entity conducts business through a branch in or undertakes any other operations in a Foreign Jurisdiction.
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d. |
“Foreign Entity Loss” means that part of the loss, liability or expense incurred by a Foreign Entity (net of any sums available therefor to that Foreign Entity under any Locally Admitted Insurance)
which would have been payable under this Bond but for the fact that Part 2 of this rider is applicable.
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e. |
“Foreign Fund” means any entity included as an Insured in Item No. 1 of the Declarations (as modified by Rider No. 1 or other rider) that (1) is an investment company, mutual fund, unit investment
trust, closed-end fund, mutual investment fund, investment trust or any other similar investment vehicle, (2) is not registered under the Investment Company Act of 1940, and (3) is organized or domiciled in a Foreign Jurisdiction.
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f. |
“Foreign Jurisdiction” means a jurisdiction outside the United States of America.
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g. |
“Locally Admitted Insurance” means any financial institution bond or similar insurance instrument issued by an insurer that is admitted, licensed or authorized in an Associated
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Foreign Jurisdiction, which bond or instrument provides coverage to a Foreign Entity in the relevant Associated Foreign Jurisdiction.
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h. |
“Non-Admitted Insurance” means any financial institution bond, or similar insurance instrument, to the extent that bond or instrument purports to provide coverage to a corporation or other entity
which is organized, domiciled, or otherwise operating or conducting business in a Foreign Jurisdiction in which the concerned insurer is not admitted, licensed, or authorized.
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i. |
“Subsidiary” means any entity more than 50% of whose outstanding securities representing the right to vote for the election of directors are owned, directly or indirectly, by a U.S. Entity and/or
one or more of its Subsidiaries.
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j. |
“U.S. Entity” means an Insured included in Item 1 of the Declarations (as modified by Rider No. 1 or other rider) that is organized or domiciled in any jurisdiction within the United States of
America.
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* * *
Except as above stated, nothing herein shall be held to alter, waive or extend any of the terms of this Bond.
EXHIBIT B
JOINT FIDELITY BOND AGREEMENT
Agreement made as of April 30, 2024, by and among certain open end funds (the “Trusts”), on behalf of each of their respective series (the “Series”), and
certain closed end funds (the “Closed End Funds”) (the Trusts and the Closed-End Funds collectively, the “NB Funds”) managed by Neuberger Berman Investment Advisers LLC (“NBIA”), each listed on Appendix A, as amended from time to time; NBIA,
the investment adviser, investment manager, and/or administrator of the NB Funds; Neuberger Berman BD LLC (“NBBD”), the distributor of the NB Funds; Neuberger Berman Asia Limited (“NBAL”), a participating affiliate of certain of the NB Funds,
and Neuberger Berman Europe Limited (“NBEL”), a sub-adviser of certain of the NB Funds; all of which are named insureds on a certain joint fidelity bond underwritten by ICI Mutual Insurance Company covering certain acts relating to the NB Funds
(the “Joint Fidelity Bond”):
WHEREAS, each NB Fund has
registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as a management investment company; and
WHEREAS, Rule 17g-1(f) under the
1940 Act requires that a registered management investment company named as an insured on a joint fidelity bond enter into a certain agreement with the other named insureds; and
WHEREAS, the NB Funds, NBIA, NBBD,
NBAL, and NBEL, each will benefit from its participation in the Joint Fidelity Bond in compliance with this Rule:
NOW, THEREFORE, it is agreed as
follows:
1. In the event any recovery is received under
the Joint Fidelity Bond as a result of a loss sustained by any NB Fund and by one or more other named insureds, then the NB Fund sustaining such loss shall receive an equitable and proportionate share of the recovery, said proportion to be
established by the ratio that its claim bears to the total amount claimed by all participants, but at least equal to the amount that such NB Fund would have received had it provided and maintained a single insured bond with the minimum coverage
required by Rule 17g-1(d)(1) under the 1940 Act.
2. This Agreement is made by each Trust, on
behalf of its respective Series, pursuant to authority granted by its Trustees, and by each Closed End Fund pursuant to authority granted by its Directors, and the obligations created hereby are not binding upon any of the Trustees of a Trust or
any of the Directors of a Closed End Fund or any of the holders of beneficial interests of a Series or a Closed End Fund individually, but are binding only upon the property of that Series or Closed End Fund and no other.
3. This Agreement may be executed in multiple
counterparts.
Signed on behalf of the following entities:
NEUBERGER BERMAN ADVISERS MANAGEMENT TRUST
NEUBERGER BERMAN ALTERNATIVE FUNDS
NEUBERGER BERMAN EQUITY FUNDS
NEUBERGER BERMAN ETF TRUST
NEUBERGER BERMAN INCOME FUNDS
NEUBERGER BERMAN HIGH YIELD STRATEGIES FUND INC.
NEUBERGER BERMAN ENERGY INFRASTRUCTURE AND INCOME FUND INC.
NEUBERGER BERMAN MUNICIPAL FUND INC.
NEUBERGER BERMAN NEXT GENERATION CONNECTIVITY FUND INC.
NEUBERGER BERMAN REAL ESTATE SECURITIES INCOME FUND INC.
NEUBERGER BERMAN ASIA LIMITED
NEUBERGER BERMAN INVESTMENT ADVISERS LLC
NEUBERGER BERMAN BD LLC
NEUBERGER BERMAN EUROPE LIMITED
By: /s/ Brian Kerrane
Brian Kerrane
APPENDIX A
The Series of each Trust and the Closed End Funds managed by Neuberger Berman Investment
Advisers LLC currently subject to this Agreement are as follows:
SERIES OF TRUSTS MANAGED BY NEUBERGER BERMAN INVESTMENT ADVISERS LLC:
NEUBERGER BERMAN ADVISERS MANAGEMENT TRUST
Mid Cap Growth Portfolio
Mid Cap Intrinsic Value Portfolio
Real Estate Portfolio
Short Duration Bond Portfolio
Sustainable Equity Portfolio
NEUBERGER BERMAN ALTERNATIVE FUNDS
Neuberger Berman Absolute Return Multi-Manager Fund
Neuberger Berman Long Short Fund
NEUBERGER BERMAN EQUITY FUNDS
Neuberger Berman Dividend Growth Fund
Neuberger Berman Emerging Markets Equity Fund
Neuberger Berman Equity Income Fund
Neuberger Berman Focus Fund
Neuberger Berman Genesis Fund
Neuberger Berman International Equity Fund
Neuberger Berman International Select Fund
Neuberger Berman International Small Cap Fund
Neuberger Berman Intrinsic Value Fund
Neuberger Berman Large Cap Growth Fund
Neuberger Berman Large Cap Value Fund
Neuberger Berman Mid Cap Growth Fund
Neuberger Berman Mid Cap Intrinsic Value Fund
Neuberger Berman Multi-Cap Opportunities Fund
Neuberger Berman Real Estate Fund
Neuberger Berman Small Cap Growth Fund
Neuberger Berman Sustainable Equity Fund
Neuberger Berman U.S. Equity Impact Fund
NEUBERGER BERMAN ETF TRUST
Neuberger Berman Carbon Transition & Infrastructure ETF
Neuberger Berman China Equity ETF
Neuberger Berman Commodity Strategy ETF
Neuberger Berman Core Equity ETF
Neuberger Berman Disrupters ETF
Neuberger Berman Flexible Credit Income ETF
Neuberger Berman Global Real Estate ETF
Neuberger Berman Next Generation Connected Consumer ETF
Neuberger Berman Option Strategy ETF
Neuberger Berman Short Duration Income ETF
Neuberger Berman Small-Mid Cap ETF
NEUBERGER BERMAN INCOME FUNDS
Neuberger Berman Core Bond Fund
Neuberger Berman Emerging Markets Debt Fund
Neuberger Berman Floating Rate Income Fund
Neuberger Berman High Income Bond Fund
Neuberger Berman Municipal High Income Fund
Neuberger Berman Municipal Impact Fund
Neuberger Berman Municipal Intermediate Bond Fund
Neuberger Berman Short Duration Bond Fund
Neuberger Berman Strategic Income Fund
CLOSED END FUNDS MANAGED BY NEUBERGER BERMAN INVESTMENT ADVISERS LLC:
Neuberger Berman High Yield Strategies Fund Inc.
Neuberger Berman Municipal Fund Inc.
Neuberger Berman Energy Infrastructure and Income Fund Inc.
Neuberger Berman Next Generation Connectivity Fund Inc.
Neuberger Berman Real Estate Securities Income Fund Inc.
Amended as of April 30, 2024
EXHIBIT C
RESOLVED, having considered (i) the aggregate value of the funds and securities of the registered investment company ("Fund") and each of its
series (if any) to which each officer or employee of the Fund and each other NB Fund, or its investment manager, investment adviser, sub-advisers, administrator or distributor may, singly or jointly with others, have access, either directly or
through authority to draw upon such funds or direct generally the disposition of such securities, (ii) the nature and terms of the arrangements made for the custody and safekeeping of the funds and securities of the various series of the Fund
and the other NB Funds, and (iii) the nature of the securities in the investment portfolios of the various series of the Fund and each other NB Fund, the Board determines that a joint fidelity bond (the "Bond") in the aggregate amount of at
least 20 Million Dollars ($20,000,000), with management having discretion to increase it up to 25 Million Dollars ($25,000,000) as management may deem necessary, is reasonable and adequate coverage to protect the Fund against larceny or
embezzlement by any one or more of such officers and/or employees; and be it further
RESOLVED, the Board approves the amount, type, form and coverage of the Bond issued by ICI Mutual Insurance Company ("ICI Mutual") and naming as insured
parties the Fund, Neuberger Berman Asia Limited (“NBAL”), Neuberger Berman Investment Advisers LLC ("NBIA"), Neuberger Berman BD LLC ("NBBD LLC"), Neuberger Berman Europe Limited ("NBEL") and
the other registered investment companies for which NBIA serves as investment manager and administrator, in the aggregate amount of at least 20 Million Dollars ($20,000,000), with management having discretion to increase it up to 25 Million
Dollars ($25,000,000) as management may deem necessary, for the period from April 30, 2024 to April 30, 2025; and be it further
RESOLVED, having taken into account (i) the number of other parties named as insureds under the Bond, (ii) the nature of the business
activities of such other insured parties, (iii) the aggregate amount of the Bond, (iv) the total amount of premium for the Bond, (v) the ratable allocation of the premium among all the insured parties, and (vi) the extent to which the share of
the premium allocable to the Fund is less than the premium it would have had to pay if it had provided and maintained a single insured bond, the Board approves the method of allocating the premium among the Fund and such other insured parties as
presented to the Board and the amount of the premium to be paid by the Fund, and approves the action taken by the officers of the Fund in arranging for the new Bond; and be it further
RESOLVED, that the Board, including majority of the Independent Trustees/Directors, hereby authorizes payment by each Fund of the amount
representing such Fund's allocable share of the annual premium on the Bond, in an amount that is to be paid 84% pro rata based on the Fund’s assets, and 16% paid by NBIA; and be it further
RESOLVED, the proper officers of the Fund are authorized and directed to execute and deliver an agreement among the Fund and the other insured
parties under the Bond setting forth the manner of disposition of any recovery received under the Bond and the manner of allocation of the premium for the Bond, in the form presented to the Board and with such changes as such officers shall, with
the advice of counsel, deem appropriate, any such determination to be conclusively evidenced by such execution and delivery.
EXHIBIT D
Amount of a Single Insured Bond which each Fund would have provided, had it not been named as an
Insured under the Joint Bond
Neuberger Berman Advisers Management Trust
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$1,500,000
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Neuberger Berman Alternative Funds |
$2,500,000
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Neuberger Berman Equity Funds
|
$2,500,000
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Neuberger Berman ETF Trust
|
$1,000,000
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Neuberger Berman Income Funds
|
$2,500,000
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Neuberger Berman Municipal Fund Inc.
|
$ 900,000
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Neuberger Berman Next Generation Connectivity Fund Inc.
|
$1,250,000
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Neuberger Berman Real Estate Securities Income Fund Inc.
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$ 600,000
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Neuberger Berman High Yield Strategies Fund Inc.
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$ 750,000
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Neuberger Berman Energy Infrastructure and Income Fund Inc.
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$ 900,000
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